Frequently Asked Questions

364. Who can apply for a specific license if an export or reexport to Iran is not authorized by general license?

… or -controlled foreign entity may apply for a specific license for the export or reexport to Iran of agricultural commodities excluded from the scope of the agricultural commodities general … such as live animals. … Who can apply for a specific license if an export or reexport to… Read more

166. OFAC’s SDN List contains a list of entities identified by OFAC as being the Government of Iran. Should U.S. persons now block the property and interests in property of those entities?

… Yes, U.S. persons should now block the property and interests in property of the Government of Iran entities appearing on the SDN List , unless OFAC has authorized the underlying transaction … … OFAC’s SDN List contains a list of entities identified by OFAC as being the… Read more

365. What is authorized with respect to brokerage services related to exports or reexports of agricultural commodities, medicine, or medical devices to Iran?

… or reexportation by U.S. persons of agricultural commodities, medicine, and medical devices to Iran, provided that the sale and exportation or reexportation itself is authorized by either … related to exports or reexports of agricultural commodities, medicine, or medical devices… Read more

607. What activity will become sanctionable on or after November 5, 2018 under E.O. 13846 or other authorities?

… including under provisions of E.O. 13846 and relevant statutory authorities: i. Sanctions on Iran’s port operators, and shipping and shipbuilding sectors, including on the Islamic Republic of Iran Shipping Lines (IRISL), South Shipping Line Iran… Read more

165. To what extent are U.S. persons expected to conduct enhanced due diligence to determine if transactions contain a Government of Iran interest?

… requires U.S. persons to block all property and interests in property of the Government of Iran, unless otherwise exempt or authorized by OFAC. Please contact the OFAC Compliance Hotline , … for guidance regarding entities that you suspect are owned or controlled by the… Read more

187. Does the GHRAVITY E.O. prohibit me from exporting technology to companies that do business with Iran or Syria?

… … This E.O. does not generally prohibit transactions involving persons that do business with Iran or Syria, unless the person has been designated pursuant to this order. You should consult … the GHRAVITY E.O. prohibit me from exporting technology to companies that do business… Read more

932. Do U.S. sanctions prohibit U.S. persons from visiting, or making donations to, the Imam Reza Holy Shrine in Mashhad, Iran?

… 932 … URGENT NOTE: The U.S. Department of State cautions against any travel by U.S. persons to Iran. The Department of State has issued a Level Four Travel Advisory ( Do Not Travel ) for Iran due to the risk of kidnapping, arbitrary arrest, and detention of U.S.… Read more

1088. What are OFAC’s due diligence expectations for cloud-based service or software providers whose services and software support communication tools are authorized by 31 CFR § 560.540?

… or software provider whose non-Iranian customers provide services or software to persons in Iran via the cloud may rely upon the authorization in 31 CFR § 560.540 to provide access to Iran, provided that such provider conducts due diligence based on information… Read more

174. What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “owned or controlled by the government of a foreign country,” “food, medicine, and medical devices,” “foreign financial institution,” “Iranian financial institution,” “significantly reduced,” and “whether the price and supply of petroleum and petroleum products produced in countries other than Iran is sufficient”?

… Financial Sanctions Regulations (IFSR), which implement section 104(c) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), identify factors to be used in … the following: The holding of nostro, vostro, or loro accounts for or with the Central Bank of… Read more

164. The Iranian Transactions Regulations (ITR) authorize U.S. depository institutions and U.S. registered brokers or dealers in securities to process transfers of funds to or from Iran if the transfer is a non-commercial, personal remittance. Are U.S. depository institutions and U.S. registered brokers or dealers in securities still authorized to process such payments to or from a Government of Iran-owned bank that is not otherwise designated pursuant to another part of 31 C.F.R. Chapter V?

… brokers or dealers in securities to process noncommercial, personal remittances to or from Iran provided that the payment is not made by, to, or through a financial institution designated … are blocked solely pursuant to E.O. 13599. Exempt or authorized transactions to or from… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence