Frequently Asked Questions

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

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

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

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

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

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

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

259. What can a foreign financial institution (FFI) do with the funds resulting from the import of Iranian-origin goods or services once the funds are credited to an account? Can funds be transferred to other accounts?

… to fall within the bounds of the significant reduction exception , any funds owed to Iran as a result of the bilateral trade transaction must be credited to an "account located in … at the same FFI that facilitated the transaction for the importation of goods or services… Read more

844. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions, or other activities that would be authorized under the Iranian Transactions and Sanctions Regulations and General License (GL) L if engaged in by a U.S. person, involving Iranian financial institutions (Iranian FIs) sanctioned pursuant to E.O. 13902?

… for engaging in the sale of agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in E.O. 13902 and other … List of Specially Designated Nationals and Blocked Persons (SDN List) in connection with … Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence