Frequently Asked Questions

538. Does OFAC aggregate ownership stakes of all entities subject to Directive 4 when determining whether a project is 33 percent or more owned by a person subject to Directive 4, or whether a person subject to Directive 4 owns a majority of the voting interests in a project?

538 … Yes. The prohibition of subsection 2 of Directive 4 applies to projects owned 33 percent or more in the aggregate by one or more Directive 4 SSI entities, their property, and their interests in property, including entities owned 50 percent or more by one or more persons determined to be… Read more

294. How will I know if someone is part of Iran’s energy, shipping, or shipbuilding sectors or is a port operator in Iran?

294 … Persons determined to be part of Iran’s energy, shipping, or shipbuilding sectors, or a port operator in Iran for purposes of IFCA section 1244(c) will be identified as such on the SDN List . Knowingly providing certain significant support to persons determined to be part of Iran’s energy,… Read more

136. What does the term "items" cover, and what is meant by items subject to the Export Administration Regulations?

136 … For the purposes of OFAC Syria General License No. 4A, "items subject to the EAR" is defined at § 734.3 of the Export Administration Regulations ("EAR"), 15 C.F.R. Parts 730-774.The EAR are administered by the U.S. Department of Commerce, Bureau of Industry and Security ("BIS"). Note that BIS… Read more

295. What are goods or services used in connection with Iran’s energy, shipping, or shipbuilding sectors for purposes of IFCA section 1244(d)(3)?

295 … We anticipate that regulations to be promulgated will define goods and services used in connection with Iran’s energy, shipping and shipbuilding sectors to include: a. Energy Sector: In the case of Iran’s energy sector, goods or services that contribute to, Iran’s ability to develop its… Read more

137. Regarding OFAC Syria General License No. 4A, will I need a specific license from OFAC to export or reexport food or medicine to the Government of Syria?

137 … The export or reexport of food or medicine that is subject to the EAR to the Government of Syria, other than medicine on the Commerce Control List that has not been licensed by BIS for export or reexport to Syria, does not require a specific license from OFAC. As set forth in the EAR, which… Read more

138. Does General License No. 4A authorize U.S. persons to export or reexport from a third country to Syria or the Government of Syria a foreign-made item with either no U.S. content or de minimis U.S. content?

138 … General License No. 4A only applies to items that are subject to the EAR, as set forth in 15 C.F.R. § 734.3. If a foreign-made item located abroad is not subject to the EAR based on the regulations administered by BIS, the exportation or reexportation of such items by U.S. persons to the… Read more

227. May I continue to send money to family or friends in Syria?

227 … Yes. Pursuant to 31 CFR § 542.512 , U.S. persons may continue to send noncommercial, personal remittances to friends or family in Syria, provided the transfer is not by, to, or through the Government of Syria or any other person whose property and interests in property are blocked. Syria… Read more

228. May I send personal remittances through the Commercial Bank of Syria, the Syrian-Lebanese Commercial Bank, or the Syria International Islamic Bank (SIIB) to family or friends in Syria?

228 … No. General License No. 6 does not authorize any transactions involving individuals or entities designated under E.O. 13382, which targets proliferators of weapons of mass destruction and their supporters, including the Commercial Bank of Syria, the Syrian Lebanese Commercial Bank, and the… Read more

296. Will the provision of bunkering services to a non-Iranian vessel carrying non-sanctionable goods to or from Iran be subject to sanctions?

296 … If a non-Iranian vessel is transporting non-sanctionable goods to or from Iran, the bunkering of that non-Iranian vessel in a country other than Iran — and related payments for these bunkering services — will not be subject to sanctions, only if (1) the transaction either does not involve U.S… Read more

205. I want to support non-governmental organizations (NGOs) that help the Syrian people. How can I do this while staying in compliance with sanctions?

205 … U.S. persons may donate funds to and raise funds on behalf of U.S. and third-country NGOs that engage in authorized activities in Syria (please see § 542.516 of the Syrian Sanctions Regulations for the full list of authorized activities). U.S. persons can also donate humanitarian goods like… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence