Frequently Asked Questions

31. What are the features and benefits that banks should be looking for when selecting an OFAC compliance software package?

There are a wide variety of software packages available to the financial community. The size and needs of each institution help to determine what to look for in a package. Some packages are used to interdict sanctioned countries and names on the Specially Designated Nationals or other sanctions… Read more

39. What do I do if I have a blocked account that needs to be escheated to the state?

You need to discuss this with your state authorities and with OFAC. Updated on April 20, 2022 …

48. I just received an interdiction "alert." What do I do?

When your interdiction software or account holder checking service shows a potential match, OFAC recommends that you do an initial analysis prior to contacting OFAC. If you have a reasonably close match to a name on the Specially Designated Nationals (SDN) list (or one of OFAC's other sanctions… Read more

72. Can I send money to a sanctioned country using a third-country company’s website? Can I buy gifts for someone in a sanctioned country over the internet? The websites tell me that it’s ok because they themselves are not sanctioned parties.

You cannot do something indirectly that you would not be able to do directly. Therefore, these sites can be used to facilitate authorized transactions, but you cannot use them to perform a transaction which would be in violation of U.S. law. For example, the Cuban Assets Control Regulations (CACR)… Read more

73. My company provides money remittance and account services via the Internet. Does OFAC have any compliance guidance for this type of business?

Complying with United States sanctions policy presents unique challenges to institutions that operate exclusively on the Internet. The Internet has often been thought of as an "anonymous venue" in that e-commerce transactions can be conducted in relative privacy with little or no face-to-face… Read more

434. Are all applications designed to run on mobile operating systems (“apps”) covered by 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?

The exportation to Iran of apps that are designated EAR99 or classified under export control classification number (ECCN) 5D992.c, as specified in category (8) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications, is authorized under 31 CFR § 560.540(a)(3),… Read more

435. Is the exportation of anti-virus, anti-malware, anti-tracking, and anti-censorship software authorized under 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?

Yes. Section 560.540(a)(3) authorizes the exportation of certain anti-virus, anti-malware, anti-tracking, anti-censorship software, and related services, as specified in categories (6), (7), and (9) of the31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications. Date… 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?

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 5D992.c,… 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)?

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) of the… Read more

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

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 is… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence