Frequently Asked Questions

1221. Can U.S. financial institutions establish relationships with Syrian financial institutions, including the Central Bank of Syria?

1221 … Yes. All Syrian financial institutions, including the Central Bank of Syria, have been removed from OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List). Effective July 1, 2025, U.S. persons are not prohibited from providing financial services to Syria, processing… Read more

1222. Do I need a specific license from OFAC to export or reexport food or medicine to Syria?

1222 … No. The United States no longer maintains comprehensive sanctions on Syria, effective July 1, 2025, following the issuance of the E.O. of June 30, 2025 . You may send U.S.-origin food or medicine to Syria without a specific license from OFAC. Furthermore, the Department of Commerce maintains… Read more

1223. Can persons continue to rely on Syria General License (GL) 25 after the revocation of the Syrian Sanctions Program, on July 1, 2025?

1223 … Yes. While Syria GL 25 authorizes transactions otherwise prohibited under the Syrian Sanctions Regulations, it also authorizes transactions involving specified persons otherwise prohibited by certain other sanctions programs. To the extent necessary, persons may continue to rely on GL 25 and… Read more

999. What authorizations exist for entities subject to Directive 4 under Executive Order (E.O.) 14024, "Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation," as amended (Russia-related Sovereign Transactions Directive)?

999 … OFAC issued Russia-related General License (GL) 115B to authorize civil nuclear energy-related transactions, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive . OFAC issued GL 13O to authorize… Read more

1118. As of December 2022, the Government of the Russian Federation may require a so-called "exit tax" payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called "exit tax"? Does Russia-related General License (GL) 13O authorize transactions that involve the payment of this exit tax?

1118 … Directive 4 under Executive Order (E.O.) 14024, "Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation," as amended (Russia-related Sovereign… 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?

259 … Section 504 of the TRA requires that, in order for a sanctionable transaction 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 the country with primary… Read more

736. May the U.S. dollar be used to conduct transactions in Cuba or with Cuban nationals?

736 … Yes, under certain circumstances. Persons subject to U.S. jurisdiction may engage in transactions in U.S. dollars in Cuba or with Cuban nationals with respect to activity that is authorized pursuant to the Cuban Assets Control Regulations (CACR) . For example, payments for telecommunications… Read more

436. What do Secure Socket Layers (SSLs), listed in the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications, encompass?

436 … SSLs, as described in category (11) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications (“31 CFR § 560.540 List”) encompass “provisioning and verification software for Secure Socket Layer (SSL) certificates designated EAR99 or classified under ECCN… Read more

437. Are mobile phone accessories and computer accessories and peripherals authorized for export under 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?

437 … Yes. Accessories for use in conjunction with hardware specified in categories (1) and (5) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications (the “31 CFR § 560.540 List), and peripherals for use in conjunction with hardware specified in category (5)… Read more

438. Is the exportation of parts or components for authorized hardware, such as microprocessors, authorized under 31 CFR § 560.540?

438 … No. While the exportation of certain accessories and peripherals specified in categories (1) and (5) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications is authorized under 31 CFR § 560.540(a)(3), the exportation to Iran of hardware parts or components… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence