Frequently Asked Questions

823. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions or activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) that U.S. persons would be authorized to engage in under General License No. 8A (GL 8A)?

823 … No. Non-U.S. persons generally do not risk exposure under U.S. secondary sanctions relating to Iran for engaging in the sale of agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in otherwise applicable authorities,… Read more

824. What is the Swiss Humanitarian Trade Arrangement (SHTA)?

824 … On October 25, 2019, the U.S. Departments of State and the Treasury announced a new humanitarian framework to assist foreign governments and foreign financial institutions in establishing payment mechanisms to facilitate humanitarian exports to Iran that are subject to enhanced due diligence… Read more

825. How can parties participate in the Swiss Humanitarian Trade Arrangement (SHTA) to export humanitarian goods to Iran?

825 … The SHTA is overseen by Switzerland's State Secretariat for Economic Affairs (SECO) and intended for use by U.S. and non-U.S. persons domiciled in Switzerland. Exporters within Swiss jurisdiction may reach out to SECO at SHTA@seco.admin.ch for further details on requirements and instructions… Read more

826. What options exist for exporting humanitarian goods to Iran outside the Swiss Humanitarian Trade Arrangement (SHTA)?

826 … Transactions for the sale of agricultural commodities, food, medicine, and medical devices are not required to be processed through the SHTA. See FAQ 637 for guidance setting out existing exceptions to U.S. sanctions for the export of humanitarian goods to Iran. Foreign governments and… Read more

593. If a blocked person holds an equity interest in a foreign entity, and the foreign entity is not itself a blocked person pursuant to OFAC’s fifty percent rule, can the foreign entity be sanctioned under section 10 of SSIDES, as amended by section 228 of CAATSA, and section 5 of UFSA, as amended by section 226 of CAATSA, for paying dividends to the blocked person?

593 … Whether paying dividends to a blocked person who holds an equity interest in the foreign company of less than fifty percent, individually or in the aggregate, would result in OFAC imposing sanctions under these authorities on the payer of the dividends depends on whether OFAC determines that… Read more

541. What activities can trigger sanctions on a foreign financial institution (FFI) under section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated into § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR)?

541 … Section 226 of CAATSA amended section 5 of UFSA to make the sanctions in that section, which were previously discretionary, mandatory. This section is implemented in § 589.209 of the URSR. Under § 589.209, FFIs face sanctions if the Secretary of the Treasury determines that they knowingly… Read more

542. How does OFAC interpret the following terms as used in section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated into § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR): “significant transaction,” “significant financial transaction,” and “facilitated?”

542 … “ Significant transaction ” and “ significant financial transaction ”– section 589.413 of the URSR states that for purposes of the UFSA prohibitions in § 589.209 , the Secretary of the Treasury will consider the totality of the facts and circumstances when determining whether transactions or… Read more

543. How will U.S. financial institutions and foreign financial institutions (FFIs) know that the Department of the Treasury has imposed prohibitions or strict conditions on FFIs’ correspondent accounts or payable-through accounts in the United States pursuant to section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated in § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR)?

543 … If, pursuant to § 589.209 of the URSR, Treasury decides to impose strict condition(s) on maintaining U.S. correspondent accounts or U.S. payable-through accounts for an FFI, or decides to prohibit the opening or maintaining of U.S. correspondent accounts or U.S. payable-through accounts for… Read more

544. What is the relationship between CAATSA and the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES)?

544 … Section 228 of CAATSA adds two sections to SSIDES that impose mandatory sanctions. … What is the relationship between CAATSA and the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 …

545. What do the following key terms in section 10 of the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES), as amended by section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), mean: “foreign person,” “knowingly,” “materially violate,” “facilitates . . . for or on behalf of,” “significant transaction,” and “deceptive or structured transaction”?

545 … “foreign person” – As stated in § 589.317 of the Ukraine-/Russia-Related Sanctions Regulations (URSR), the term foreign person for purposes of the SSIDES section 10 provisions in §§ 589.201(a)(6) and 589.413 means any citizen or national of a foreign state (including any such individual who… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence