Frequently Asked Questions

670. Are there exceptions to the sanctions imposed under E.O.13871?

670 … Yes. The sanctions authorized under E.O. 13871 do not apply to transactions for the conduct of the official business of the United States Government or the United Nations (including its specialized agencies, programmes, funds, and related organizations) by employees, grantees, or contractors… Read more

671. How are the terms “significant transaction or transactions; significant financial services; significant financial transaction” interpreted for purposes of correspondent or payable-through account sanctions set forth in section 2 of E.O. 13871?

671 … The interpretation of “significant transaction or transactions; significant financial services; significant financial transaction,” as described in the correspondent account sanctions in the IFSR, provides that the Department of the Treasury may consider the totality of the facts and… Read more

683. How is the term “significant transaction or transactions” interpreted for purposes of blocking sanctions set forth in section 1 of E.O. 13871?

683 … The interpretation of “significant transaction or transactions,” as described in the ISHR provides that the Department of the Treasury may consider the totality of the facts and circumstances and sets forth a list of broad factors that can play a role in the determination whether transactions… Read more

684. What is the definition of the “iron sector of Iran”?

684 … The term iron sector of Iran means the mining, refining, processing, or manufacturing of iron or iron products in Iran. (31 C.F.R. § 561.336; 31 C.F.R. § 561.317). … What is the definition of the “iron sector of …

685. What is the definition of the “steel sector of Iran”?

685 … The term steel sector of Iran means the iron-ore smelting, ferrous-scrap melting, refining, processing, or manufacturing of steel or steel products in Iran. (31 C.F.R. § 561.337; 31 C.F.R. § 562.318). … What is the definition of the “steel sector of …

623. Is there a wind-down or safe harbor provision for Section 8 of E.O. 13846?

623 … No. Section 8 of E.O. 13846 continues in effect the prohibition previously contained in section 4 of E.O. 13628, which — consistent with subsection 218(d) of the TRA — provided that civil penalties would not apply if a U.S. person that owns or controls the foreign entity divested or… Read more

565. For purposes of E.O. 13827 "Taking Additional Steps to Deal with the Situation in Venezuela" of March 19, 2018, is Venezuela’s traditional fiat currency, bolivar fuerte, considered a “digital currency, digital coin, or digital token” that was issued by, for, or on behalf of the Government of Venezuela on or after January 9, 2018?

565 … Answer: No. … For purposes of E.O. 13827 "Taking Additional Steps to Deal with the Situation in Venezuela" of March 19, 2018, is Venezuela’s traditional fiat currency, bolivar fuerte, considered a “digital currency, digital coin, or digital token” that was issued by, for, or on behalf of the… Read more

566. I participated in the pre-sale for a Government of Venezuela-issued “digital currency, digital coin, or digital token” before E.O. 13827 "Taking Additional Steps to Deal with the Situation in Venezuela" of March 19, 2018, became effective. Am I allowed to sell, trade, use, or otherwise deal in such “digital currency, digital coin, or digital token” on or after the sanctions effective date?

566 … Absent authorization from OFAC, U.S. persons are prohibited from engaging in transactions related to, providing financing for, and otherwise dealing in any “digital currency, digital coin, or digital token” that was issued by, for, or on behalf of the Government of Venezuela on or after… Read more

515. For purposes of Executive Order (E.O.) 13808 is the term "new equity" limited to equity that is issued by an entity owned or controlled by the Government of Venezuela after the sanctions effective date, or would equity purchased or acquired by an entity owned or controlled by the Government of Venezuela from a third party after the sanctions effective date be considered new equity?

515 … Under E.O. 13808 , the term "new equity" pertains to equity issued, directly or indirectly, by the Government of Venezuela on or after August 25, 2017. That said, E.O. 13808 also prohibits U.S. persons from purchasing any securities – including equity securities issued by a non-sanctioned… Read more

595. What does Venezuela-related General License 5Q authorize?

595 … The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence