Frequently Asked Questions

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

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

263. Who can receive payments from funds credited to a RECIPIENT ACCOUNT or SPECIAL PURPOSE ACCOUNT?

… 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

258. What is meant by the TRA section 504’s requirement that bilateral trade consist of trade in goods and services between the country with primary jurisdiction over the foreign financial institution (FFI) and Iran?

… 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 import… Read more

296. Will the provision of bunkering services to a non-Iranian vessel carrying non-sanctionable goods to or from Iran be subject to sanctions?

… 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 and… Read more

254. What does section 504 of the TRA do?

… 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

487. Are goods that are unloaded from a ship in an Iranian port, put on a truck, and driven out of the boundaries of the port or place of unloading considered to be Iranian-origin goods?

… 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

488. Are goods that are unloaded from a ship in an Iranian port, moved within the boundaries of the port, and loaded onto a second ship en route to a destination outside of Iran, without ever leaving the port considered to be Iranian-origin goods?

… No, provided that they have not otherwise come in contact with Iran. … the boundaries of the port, and loaded onto a second ship en route to a destination outside of Iran, without ever leaving the port considered to be Iranian-origin goods? … No, provided that… Read more

825. How can parties participate in the Swiss Humanitarian Trade Arrangement (SHTA) to export humanitarian goods to Iran?

… 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

614. What does E.O. 13846 do with respect to Iran’s energy, petroleum, and petrochemical sectors?

… sale, transport, or marketing of petroleum, petroleum products, or petrochemicals from Iran, with the aim of deterring Iran or any other country or institution from establishing workaround payment mechanisms for the … supply, or transfer to or from Iran… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence