Frequently Asked Questions

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

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 … 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 … 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 … “ 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

611 … E.O. 13846 reimposes sanctions on certain transactions on or after August 7, 2018, for the sale, supply, or transfer to Iran of “significant” goods or services used in connection with the automotive sector of Iran. (See FAQ 289 for an interpretation of the term “significant.”) We anticipate… Read more

267 … These definitions are set out in 31 CFR Part 561 . … What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “food, medicine, and medical devices,” “foreign financial institution,” and “country with primary jurisdiction over the …

612 … E.O. 13846 does not make sanctionable the export of finished vehicles to Iran if no further assembly or manufacturing is required. As such, exporting fully assembled and finished vehicles to Iran for sale would not be sanctionable, so long as the transaction is consistent with U.S. sanctions… Read more

613 … Goods or services for the maintenance of finished vehicles exported to Iran would generally not be considered “significant goods or services used in connection with the automotive sector of Iran” for the purposes of E.O. 13846 , and the provision of such goods or services would generally not… Read more

313 … IFCA was signed into law on January 2, 2013, as a part of the National Defense Authorization Act for Fiscal Year 2013, and provides for several new sanctions related to Iran. IFCA authorizes broad sanctions on: certain activities related to Iran’s energy, shipping, and shipbuilding sectors;… Read more