Frequently Asked Questions

The ITSR include several general licenses that newly authorize, or continue to authorize, activities that are otherwise prohibited by the regulations. Categories of activities affected by these changes include, among other things, visa-related transactions, journalistic activities in Iran, the sale… Read more

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 under… Read more

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

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

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 Authorization… Read more

Yes. Authorized travelers in Cuba are permitted to use credit or debit cards issued by a U.S. financial institution with respect to activity that is authorized pursuant to the CACR . Travelers are advised to check with their financial institution before traveling to Cuba to determine whether the… Read more

OFAC regulations do not require financial institutions or credit card companies to accept, maintain, or facilitate authorized financial relationships or transactions. …

Yes, credit card network operators that are persons subject to U.S. jurisdiction may process such transactions and related settlements for third-country financial institutions. Section 515.584 (c) of the CACR authorizes all transactions incident to the processing and payment of credit and debit… Read more

Yes. Section 515.584(c) of the CACR authorizes all transactions incident to the processing and payment of credit and debit cards transactions for third-country nationals traveling to, from, or within Cuba. Any person subject to U.S. jurisdiction, including U.S. financial institutions and their… Read more

E.O. 13722 blocks the Government of North Korea and the Workers’ Party of Korea; prohibits the exportation and reexportation of goods, services (including financial services), and technology to North Korea; and prohibits new investment in North Korea. E.O. 13722 also adds new designation criteria,… Read more