Frequently Asked Questions

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

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?

… 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 Iran… 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 … Does the GHRAVITY E.O. prohibit me from exporting technology to companies that do business… 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

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 … 211(a) and 212(a) of TRA, and subsections 1246(a) and 1247(a) of IFCA); and vi. Sanctions… 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

203. Can a U.S. person use a listed person to facilitate personal remittances to or from Iran or Syria?

… Can a U.S. person use a listed person to facilitate personal remittances to or from Iran or Syria? … Can a U.S. person use a listed person to facilitate personal remittances to or from Iran or Syria? …

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

150. Where can I find a list of Islamic Revolutionary Guard Corps (IRGC) affiliates and Iran-linked financial institutions “blocked pursuant to the International Emergency Economic Powers Act (IEEPA)”?

… The list of blocked IRGC affiliates and blocked Iran-linked financial institutions is dynamic and is based on the identity of “designated” … listings of designated IRGC entities will be followed by the tag [IRGC]; those of designated Iran-linked financial… 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