Frequently Asked Questions

176. If oil is being provided as payment for an outstanding debt, is such a transfer considered a “financial transaction”?

176 … If a transfer involves a financial institution it would likely be considered a financial transaction . … If oil is being provided as payment for an outstanding debt, is such a transfer considered a “financial …

177. If the Central Bank of Iran (CBI) is involved in providing settlement services for a transaction, or is otherwise acting solely as an intermediary in a transaction between a non-designated Iranian bank and a foreign financial institution, is the foreign financial institution deemed to be engaging in a transaction with the CBI?

177 … Section 1245 targets any significant transactions “with” the CBI; a transaction involving the CBI in an intermediary role would likely be viewed as a transaction “with” the CBI. … If the Central Bank of Iran (CBI) is involved in providing settlement services for a transaction, or is otherwise… Read more

178. Are barter trades involving the Central Bank of Iran (CBI) considered “financial transactions” under Section 1245?

178 … If a transfer involves a financial institution it would likely be considered a financial transaction . … Are barter trades involving the Central Bank of Iran (CBI) considered “financial transactions” under Section …

338. With respect to the authorizations in 31 CFR § 560.540(a)(1) and (a)(2) of the Iranian Transactions and Sanctions Regulations (ITSR), what services and software are covered?

338 … Qualifying services under 31 CFR § 560.540(a)(1) are those that are “incident to the exchange of communications over the internet,” as well as cloud-based services in support of such services or of any other transaction authorized or exempt under the ITSR. Qualifying software under 31 CFR §… Read more

179. Does the definition of “significant financial transaction” exclude the passive holding of Central Bank of Iran (CBI) reserves? Is the U.S. willing to give assurances that this will not be a basis for sanctions?

179 … This will be a case-by-case determination and will require specifics on what “passive holding” entails. As a general matter, we would likely not view the holding of reserves as sanctionable in the following circumstances: the accounts are frozen or restricted, under which the CBI would be… Read more

180. Are payments made under contracts existing prior to the date of enactment of the National Defense Authorization Act (NDAA) statute (December 31, 2011) exempted from the definition of “significant transactions”?

180 … No general exception will be provided for payments arising out of pre-existing contracts. The assessment of whether such payments are “significant” will be done on a case-by-case basis in line with the criteria discussed in FAQ #174 . … Are payments made under contracts existing prior to the… Read more

181. Will the U.S. refrain from sanctioning foreign financial institutions that receive funds from the Central Bank of Iran (CBI) to repay loans? What if these loans were granted for projects that might be subject to the food, medicine, and medical device exemptions under the National Defense Authorization Act (NDAA)?

181 … As noted , no general exception will be provided for payments arising out of pre-existing contracts. The assessment of whether such payments are “significant” will be done on a case-by-case basis in line with the criteria discussed in FAQ #174 . Regarding payments for food, medicine, and… Read more

182. Is there a difference between entities that have been designated by the United States Government for illicit conduct, such as proliferation of weapons of mass destruction or support for terrorism, and those that are being blocked under E.O. 13599? How can I tell which entities appear on the Specially Designated National (SDN) List for which reasons?

182 … Both blocked and designated entities appear on the SDN List . “Blocked” persons, in the context of E.O. 13599 , appear on the SDN List due to the United States Government’s identification of these entities as the Government of Iran and/or as an Iranian financial institution . Such entities… Read more

339. With respect to the authorization in 31 CFR § 560.540(a)(3), do exporters need to make a determination as to whether an export of an item or service included in the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications is “incident to communications”?

339 … No. The 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications lists software, hardware, and related services determined to be “incident to communications” for purposes of the authorization in 31 CFR § 560.540(a)(3) of the ITSR. Date Updated: May 16, 2024 … With… Read more

183. Why did the President issue the GHRAVITY E.O.?

183 … The GHRAVITY E.O. follows prior Executive orders issued by the President in response to the commission of human rights abuses by the Governments of Iran and Syria. With the GHRAVITY E.O., the President recognized that the commission of serious human rights abuses against the people of Iran… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence