Frequently Asked Questions

… States if they knowingly engage in significant financial transactions with the Central Bank of Iran (“CBI”) or a designated Iranian financial institution, unless an NDAA exception, such as the … facilitate bilateral trade in goods or services between the country granted the… Read more

… 296 … If a non-Iranian vessel is transporting non-sanctionable goods to or from Iran, the bunkering of that non-Iranian vessel in a country other than Iran — and related payments for these bunkering services — will not be subject to sanctions, only … Nationals… Read more

… 118 … No. As long as you are satisfied that the client is not ordinarily resident in Iran, then the account does not need to be restricted. See FAQ 37 .  … I have a client that is in Iran to visit a relative. Do I need to restrict the account? …

… … In the absence of information proving to your satisfaction that the account holder is not in Iran, you should consider the account restricted based on the W-8 filing. See FAQ 37 . … I have an account with a W-8 showing an address in Iran. Is the account… Read more

… 258 … OFAC interprets bilateral trade between Iran and the country with primary jurisdiction over the FFI to mean trade in only those goods or … with primary jurisdiction over the FFI conducting or facilitating the transaction, or (ii) Iran (for purposes of the… Read more

… payment (e.g., the manufacturer or service provider) for goods or services being exported to Iran must be – (i) a citizen, national, or permanent resident of the country with primary … accounts. Furthermore, the person receiving such payment may not be - (i) the Government of… Read more

… Regulations, 31 C.F.R. part 560 (ITSR), when conducting exports of humanitarian goods to Iran. Certain exports and sales of humanitarian goods to Iran are authorized pursuant to sections 560.530, 560.532, and 560.533 of the ITSR. In addition, … for such… Read more

… from knowingly engaging in any transaction, directly or indirectly, with the Government of Iran or any person subject to the jurisdiction of the Government of Iran that would be prohibited by the ITSR if engaged in by a U.S. person or in the United States. …

… of, the purchase or acquisition of U.S. bank notes or precious metals by the Government of Iran, or (ii) on or after November 5, 2018, materially assisted, sponsored, or provided … Iranian Oil Company (NIOC), the Naftiran Intertrade Company (NICO), or the Central Bank of … Read more

… 487 … Yes. These goods have otherwise come in contact with Iran and thus do not fall within the carve-out to the definition of Iranian-origin goods or goods … 560.306 (b)(2) of the ITSR . However, if these goods are being exported or reexported to Iran under an… Read more