Frequently Asked Questions

245. What does the Statement of Licensing Procedure on Support of Human Rights-, Humanitarian-, and Democracy-Related Activities with Respect to Iran do?

245 … The Statement of Licensing Procedure reflects procedures established pursuant to section 413 of the Iran Threat Reduction and Syria Human Rights Act (the TRA). These procedures stipulate that, as of the effective date of the TRA, license determinations for complete requests for authorization… Read more

254. What does section 504 of the TRA do?

254 … Pursuant to the restrictions already in place under the National Defense Authorization Act (NDAA), foreign financial institutions (“FFIs”) face restrictions on, or loss of, correspondent and payable-through account access in the United States if they knowingly engage in significant financial… Read more

255. Do the section 504 modifications of the TRA restrict any other dealings with Iran?

255 … Yes, the section 504 modifications also narrow the scope of transactions excepted from certain sanctions available under E.O. 13622 . Accordingly, foreign financial institutions (FFIs) in countries that are determined by the Secretary of State to have significantly reduced their purchases of… Read more

256. What transactions are impacted by section 504 of the TRA as it amends section 1245 of the National Defense Authorization Act (NDAA) for Fiscal Year 2012?

256 … Significant financial transactions* knowingly conducted or facilitated by a foreign financial institution (FFI) with the Central Bank of Iran (CBI) on or after November 5, 2018 or with a designated Iranian financial institution may be subject to sanctions under the National Defense… Read more

257. To which jurisdictions does the significant reduction exception apply (section 504 of the TRA)?

257 … As of February 6, 2013, 20 jurisdictions have been granted a 180-day significant reduction exception . The following jurisdictions received their 180-day significant reduction exception to the National Defense Authorization Act (NDAA) sanctions on September 14, 2012: Belgium, the Czech… Read more

258. What is meant by the TRA section 504’s requirement that bilateral trade consist of trade in goods and services between the country with primary jurisdiction over the foreign financial institution (FFI) and Iran?

258 … OFAC interprets bilateral trade between Iran and the country with primary jurisdiction over the FFI to mean trade in only those goods or services originating in (e.g., produced in or substantially transformed in) – (i) the country with primary jurisdiction over the FFI conducting or… Read more

259. What can a foreign financial institution (FFI) do with the funds resulting from the import of Iranian-origin goods or services once the funds are credited to an account? Can funds be transferred to other accounts?

259 … Section 504 of the TRA requires that, in order for a sanctionable transaction to fall within the bounds of the significant reduction exception , any funds owed to Iran as a result of the bilateral trade transaction must be credited to an “account located in the country with primary… Read more

789. May persons subject to U.S. jurisdiction who open an authorized business or physical presence, such as a joint venture, office, or retail outlet, in Cuba market their telecommunications or internet-based services?

789 … Persons subject to U.S. jurisdiction that are providers of telecommunications or internet-based services who establish a business or physical presence in Cuba pursuant to the authorization in 31 CFR § 515.573 are authorized to engage in marketing related to that business or physical presence… Read more

790. Are persons subject to U.S. jurisdiction engaging in authorized transactions permitted to enter into arrangements with Cuban state-owned entities, such as ETECSA?

790 … Individuals or entities subject to U.S. jurisdiction engaging in authorized transactions, either pursuant to a general or specific license, may engage with Cuban state-owned entities as authorized by the OFAC license. For example, a U.S. company engaging in authorized telecommunications-… Read more

649. What does Executive Order 13857 of January 25, 2019 “Taking Additional Steps to Address the National Emergency with Respect to Venezuela” do and how does this impact OFAC’s Venezuela-related sanctions?

649 … Executive Order 13857 of January 25, 2019 “Taking Additional Steps to Address the National Emergency with Respect to Venezuela” broadens the definition of the term “Government of Venezuela” to include persons that have acted, or have purported to act, on behalf of the Government of Venezuela… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence