Frequently Asked Questions

635. Can I, as a U.S. person or U.S.-owned or -controlled foreign entity, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period under an OFAC wind-down authorization and pursuant to a contract entered into prior to May 8, 2018?

635 … The wind-down authorizations allow U.S. persons and U.S.-owned or -controlled foreign entities to receive payments for activities conducted pursuant to such wind-down authorizations only during their validity periods. For example, a U.S.-owned or -controlled foreign entity may receive payment… Read more

636. Can I receive payment for activities undertaken during the wind-down period if the payment involves a person that has been added to the SDN List, including a person that was previously on the List of Persons Blocked Solely Pursuant to E.O. 13599 (the “E.O. 13599 List”) but is now designated under another authority?

636 … The United States intends to fully enforce the sanctions that apply to persons that were previously on the E.O. 13599 List but that are now designated under another authority. U.S. persons and U.S.-owned or -controlled foreign entities generally would require an OFAC authorization to receive… Read more

637. Is it sanctionable for non-U.S., non-Iranian persons to engage in transactions related to the provision of humanitarian and consumer goods to Iran?

637 … The United States maintains broad authorizations and exceptions under U.S. sanctions that allow for the sale of agricultural commodities, food, medicine, and medical devices to Iran from the United States or by U.S. persons or U.S.-owned or -controlled foreign entities. U.S. sanctions laws… Read more

638. What happened to the E.O. 13599 List?

638 … The E.O. 13599 List was created to clarify that, regardless of their removal from the SDN List on January 16, 2016, persons that OFAC had previously identified as meeting the definition of the terms “Government of Iran” or “Iranian financial institution” still met those definitions and… Read more

639. Why are some persons that had been blocked solely pursuant to E.O. 13599 now designated pursuant to other authorities, such as E.O. 13224 and E.O. 13382?

639 … OFAC designated multiple Iranian financial institutions and other persons previously blocked solely pursuant to E.O. 13599 under E.O. 13224 (relating to counterterrorism), E.O. 13382 (relating to WMD proliferation), and E.O. 13553 (relating to serious human rights abuses by the Government of… Read more

621. What is the prohibition on U.S.-owned or -controlled foreign entities, and how does it work?

621 … Consistent with Section 218 of TRA , section 8 of E.O. 13846 continues in effect the sanctions previously contained in section 4 of E.O. 13628 and expands them to cover activity sanctionable under E.O. 13846 (see FAQ 601 ). This provision prohibits a U.S.-owned or -controlled foreign entity… Read more

640. What does the November 5, 2018 amendment to the ITSR do?

640 … This regulatory amendment does two things. First, it amends the ITSR to reflect the re-imposition of ITSR-related sanctions lifted under the JCPOA, including sanctions pursuant to certain sections of E.O. 13846 and the relisting on the SDN List of persons included on the E.O. 13599 List. More… Read more

641. If a country with primary jurisdiction over a foreign financial institution did not receive a significant reduction exception (SRE) under section 1245(d)(4)(D) of the NDAA 2012, can funds currently held at the foreign financial institution in that country on behalf of the Central Bank of Iran be used to facilitate humanitarian trade with Iran?

641 … Yes. Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran involving the Central Bank of Iran are excepted from the relevant sanctions under section 1245(d)(2) of the NDAA 2012 and sections 561.203 and 561.204 of the Iranian Financial Sanctions… Read more

642. Is the provision of certain associated services relating to the purchase of petroleum or petroleum products from Iran by persons in a country that has been granted a SRE sanctionable?

642 … Many U.S. sanctions related to Iran include an exception for countries that have received a SRE under section 1245(d)(4)(D) of the NDAA 2012 (see https://ofac.treasury.gov/faqs/topic/1551 for additional information regarding the implementation of the SRE and sanctionable transactions). To… Read more

643. Is payment of Iran-related insurance or reinsurance claims made on or after November 5, 2018 sanctionable if the claim arises from an incident that occurred prior to November 5, 2018?

643 … Payment of Iran-related insurance or reinsurance claims arising from incidents that occurred prior to November 5, 2018 could create sanctions exposure for non-U.S. persons to the extent such payment involves a person designated in connection with Iran’s proliferation of WMD or support for… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence