Frequently Asked Questions

256. What transactions are impacted by section 504 of the TRA as it amends section 1245 of the National Defense Authorization Act (NDAA) for Fiscal Year 2012?

… conducted or facilitated by a foreign financial institution (FFI) with the Central Bank of Iran (CBI) on or after November 5, 2018 or with a designated Iranian financial institution may be … (ii) the significant financial transaction is for bilateral trade only, and any funds… Read more

829. Following the Secretary of State’s announcement on May 27, 2020 that he will be ending certain Iran nuclear-related waivers, will there be a wind-down period for persons engaged in activity permitted by these waivers?

… waivers associated with the Arak reactor modernization redesign, the transfer into Iran of enriched uranium for the Tehran Research Reactor, and the transfer out of Iran of certain nuclear fuel scrap and of spent research reactor fuel will have a final, 60-day …… Read more

605. How does E.O. 13846 relate to various Iran-related statutes?

… States of persons determined to have engaged in the transfer of goods or technologies to Iran that are likely to be used by the GOI or any of its agencies or instrumentalities to commit serious human rights abuses against the people of Iran or the provision of… Read more

455. Is the provision of routine goods and services by non-U.S. persons to diplomatic missions of the Government of Iran located outside the United States sanctionable under U.S. law?

… for the conduct of the official business of the diplomatic missions of the Government of Iran located outside the United States or for the personal use of the employees of the missions, … Persons (other than any political subdivision, agency, or instrumentality of the Government… Read more

823. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions or activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) that U.S. persons would be authorized to engage in under General License No. 8A (GL 8A)?

… No. Non-U.S. persons generally do not risk exposure under U.S. secondary sanctions relating to Iran for engaging in the sale of agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in… Read more

609. What does E.O. 13846 do with respect to the sanctions on Iran’s automotive sector?

… for certain transactions, on or after August 7, 2018, for the sale, supply, or transfer to Iran of significant goods or services used in connection with Iran’s automotive sector. … What does E.O. 13846 do with respect to the sanctions on Iran’s …

37. My bank operates accounts for individuals living in Iran. OFAC has told us that these accounts cannot be operated. Does this mean that the accounts are blocked?

… the accounts are restricted. The Iranian sanctions prohibit the export of goods or services to Iran. By operating an account for an individual or company in Iran, the bank would be exporting services to that person or entity in violation of the Iranian … her… Read more

483. How does an exporter determine which medical devices need to be specifically licensed by OFAC for exportation or reexportation to Iran?

… Devices Requiring Specific Authorization , which is maintained on OFAC’s website, on the Iran Sanctions page . An exporter must obtain a specific license from OFAC to export or reexport any medical device on that list to Iran. An exporter must also obtain a… Read more

669. Does E.O. 13871 expand upon existing sanctions relating to trade with Iran in certain raw and semi-finished metals, such as aluminum and steel?

… section 1245 of IFCA on the sale, supply, or transfer, directly or indirectly, to or from Iran of certain materials, including raw and semi-finished metals such as aluminum and steel, as … or (C) of IFCA. In addition, E.O. 13871 explicitly targets the iron and copper sectors of… Read more

1089. Can persons seeking to export software, services, or hardware to Iran in support of internet freedom apply for a specific license from OFAC if the export is not authorized by 31 CFR § 560.540?

… 1089 … Yes, persons seeking to export software, services, or hardware to Iran or conduct other activities in support of internet freedom in Iran that are not exempt transactions or authorized by the general license in 31 CFR § 560.540 or … Date Updated: May 16,… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence