Frequently Asked Questions

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

172. How does Executive Order 13599, “Blocking Property of the Government of Iran and Iranian Financial Institutions,” and the blocking of all Iranian financial institutions affect the financial sanctions provisions in CISADA? Do CISADA sanctions now apply to financial transactions with any Iranian financial institution?

… 172 … The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) applies to transactions with only those Iranian financial institutions that are designated in connection with Iran’s WMD or terrorism activities and are denoted on OFAC’s List of… Read more

192. Why was this authority needed?

… foreign persons determined to have violated or attempted to violate U.S. sanctions on Syria or Iran, or to have facilitated deceptive transactions on behalf of persons subject to those … may use this authority where it appears that a foreign person violated U.S. sanctions on… Read more

824. What is the Swiss Humanitarian Trade Arrangement (SHTA)?

… institutions in establishing payment mechanisms to facilitate humanitarian exports to Iran that are subject to enhanced due diligence. While the United States maintains broad exceptions and authorizations for the conduct of humanitarian trade with Iran, this… 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?

… 488 … No, provided that they have not otherwise come in contact with Iran. … 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… Read more

345. How can U.S. companies arrange for payment from Iran for exports authorized under 31 CFR § 560.540?

… or U.S. registered brokers or dealers in securities may process transfers of funds from Iran or for or on behalf of a person in Iran that are in furtherance of a transaction authorized under 31 CFR § 560.540, provided the … CFR § 560.516(a). Date Updated: May 16… Read more

856. How will transactions related to Iran’s participation in legal proceedings, including administrative, judicial, arbitral proceedings, and proceedings before international courts and tribunals, be treated for purposes of secondary sanctions to the extent that Iranian financial institutions or the Iranian financial sector sanctioned under Executive Order (E.O.) 13902 are involved?

… as transactions or activities related to the defense of individuals in legal proceedings in Iran brought by the Government of Iran, including any arrest, investigation, prosecution, or detention. Such permissible … List of Specially Designated Nationals and… Read more

606. What activity will become sanctionable on or after August 7, 2018 under E.O. 13846 or other authorities?

… dollar banknotes by the GOI (see, e.g., subsection 1(a)(i) of E.O. 13846); ii. Sanctions on Iran’s trade in gold or precious metals (see, e.g., subsection 1(a)(i) of E.O. 13846 and … of IFCA ); iii. Sanctions on the direct or indirect sale, supply, or transfer to or from … Read more

266. Does the November 8, 2012 designation of National Iranian Oil Company (NIOC) under E.O. 13382 impact the scope of permissible transactions by foreign financial institutions (FFIs) in significantly reducing countries?

… 266 … Yes. On September 24, 2012, NIOC was identified as an agent or affiliate of Iran’s Islamic Revolutionary Guard Corps (“IRGC”) under section 312 of the TRA , and designated … E.O. 13382 for providing services and support to the IRGC. Accordingly, the Comprehensive … Read more

319. Does the GL for medical devices authorize the exportation or reexportation of these items to all entities in Iran?

… ( ITSR ) authorizes exports or reexports of certain medical devices to most entities in Iran, it does not authorize exports or reexports to military, intelligence, or law enforcement … medical devices authorize the exportation or reexportation of these items to all entities in… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence