Frequently Asked Questions

839. Are authorized travelers who have initiated travel arrangements prior to the addition of a property on the State Department’s Cuba Prohibited Accommodations List required to cancel their Cuba-related travel plans if their travel arrangements involve lodging at a listed property?

839 … Consistent with the Administration’s interest in avoiding negative impacts on Americans for arranging lawful travel to Cuba, any existing travel-related arrangements that include lodging at properties in Cuba identified on the Cuba Prohibited Accommodations List will continue to be permitted… Read more

840. If an official of the Government of the Hong Kong Special Administrative Region (HKSAR) is designated as a Specially Designated National (SDN), does that mean that the HKSAR government is blocked? What are the prohibitions on U.S. persons dealing with a designated HKSAR government official?

840 … The designation of an official of the Government of the HKSAR does not itself block the HKSAR government or any government agency where the SDN is an official or otherwise exercises control. Accordingly, engaging in a routine interaction with an agency in which an SDN is an official, but… Read more

842. What does General License L (GL L) authorize with respect to the financial sector of Iran and Iranian financial institutions (Iranian FIs) now sanctioned pursuant to Executive Order (E.O.) 13902?

842 … GL L authorizes under E.O. 13902 all transactions and activities involving Iranian FIs blocked pursuant to E.O. 13902 that are authorized, exempt, or otherwise not prohibited under the Iranian Transactions and Sanctions Regulations (ITSR). E.O. 13902, which was issued on January 10, 2020, is… Read more

843. I’m a U.S. person that relied on general or specific licenses issued pursuant to the Iranian Transactions and Sanctions Regulations (ITSR) to conduct humanitarian-related or other transactions and activities prior to the identification of the financial sector of Iran and sanctioning of a number of Iranian financial institutions (Iranian FIs) under E.O. 13902. Is any further authorization needed to conduct such transactions following these actions?

843 … No. General License (GL) L extends authorizations provided through specific and general licenses issued under the ITSR to apply to transactions and activities involving Iranian FIs blocked pursuant to E.O. 13902 . Further authorization from OFAC beyond GL L is not required under E.O. 13902… Read more

844. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions, or other activities that would be authorized under the Iranian Transactions and Sanctions Regulations and General License (GL) L if engaged in by a U.S. person, involving Iranian financial institutions (Iranian FIs) sanctioned pursuant to E.O. 13902?

844 … No. Non-U.S. persons generally do not risk exposure to U.S. secondary sanctions for engaging in the sale of agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in E.O. 13902 and other applicable sanctions authorities… Read more

845. Will there be a wind-down period for non-U.S. persons engaged in previously non-sanctionable activity involving the Iranian financial sector or Iranian financial institutions (FIs) that are now sanctioned pursuant to E.O. 13902?

845 … Yes. Non-U.S. persons engaged in transactions and activities involving the Iranian financial sector or any Iranian FI sanctioned pursuant to E.O. 13902 that were not previously sanctionable will have 45 days to conclude these activities without risking exposure to sanctions. The 45-day wind… Read more

846. How do the sanctions imposed on the Iranian financial sector and Iranian financial institutions (FIs) pursuant to Executive Order (E.O.) 13902 affect waivers issued by the Department of State and exceptions set forth in the Iranian Freedom and Counter-proliferation Act of 2012 (IFCA)?

846 … Waivers issued by the Department of State (State) and exceptions set forth in IFCA remain valid and activities conducted under them involving Iranian FIs are not sanctionable during the wind-down period described in FAQ 845 . Persons engaged in transactions or activities involving the… Read more

847. As a result of the sanctions on the Iranian financial sector and certain Iranian financial institutions (Iranian FIs) pursuant to Executive Order (E.O.) 13902, do non-U.S. persons risk exposure to sanctions for continuing to engage in previously non-sanctionable trade involving the Iranian financial sector or E.O. 13902-sanctioned Iranian FIs, even after the end of the 45-day wind-down period?

847 … For purposes of E.O. 13902, OFAC would not generally view transactions or activities by non-U.S. persons to be sanctionable if they are consistent with activities that would be permissible if conducted by U.S. persons. As noted in FAQ 842 , General License (GL) L authorizes U.S. persons to… Read more

848. What are the sanctions implications of the Secretary of State’s October 14, 2020 report to Congress pursuant to section 5(a) of the Hong Kong Autonomy Act (HKAA), and subsequent updates of this report, identifying foreign persons that are materially contributing to, have materially contributed to, or attempt to materially contribute to the failure of the Government of China to meet its obligations under the Joint Declaration or the Basic Law?

848 … Pursuant to section 5(a) of the HKAA , the Secretary of State submitted a report (“Section 5(a) Report”) on October 14, 2020 to the appropriate congressional committees and leadership identifying foreign persons that the Secretary of State, in consultation with the Secretary of the Treasury,… Read more

849. Can a foreign financial institution (FFI) be excluded or removed from the Section 5(b) Report so that sanctions under the Hong Kong Autonomy Act (HKAA) would not apply?

849 … Pursuant to section 5(d)(2) of the HKAA , an FFI may be excluded from the Section 5(b) Report or an update to that report under section 5(e) of the HKAA, or may be removed from the Section 5(b) Report or an update to that report prior to the imposition of sanctions under section 7(a), if the… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence