Frequently Asked Questions

170. What activities can trigger sanctions on a foreign financial institution under the NDAA?

170 … For private financial institutions, the Act mandates that the President sanction those institutions that are found to knowingly conduct or facilitate any significant transactions with a U.S.-designated Iranian financial institution or with the Central Bank of Iran (CBI) – whether for the… Read more

171. Does the NDAA (National Defense Authorization Act) repeal or amend Section 104(c) of CISADA (the Comprehensive Iran Sanctions, Accountability, and Divestment Act)?

171 … No. Any foreign financial institution that knowingly facilitates significant transactions or provides significant financial services for a U.S.-designated, Iranian-linked financial institution can be sanctioned under section 104(c) of CISADA and section 561.201 of the Iranian Financial… Read more

172. How does Executive Order 13599, “Blocking Property of the Government of Iran and Iranian Financial Institutions,” and the blocking of all Iranian financial institutions affect the financial sanctions provisions in CISADA? Do CISADA sanctions now apply to financial transactions with any Iranian financial institution?

172 … The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) applies to transactions with only those Iranian financial institutions that are designated in connection with Iran’s WMD or terrorism activities and are denoted on OFAC’s List of Specially Designated Nationals and… Read more

173. Are there any exceptions to the sanctions provisions in the National Defense Authorization Act for Fiscal Year 2012 (as amended) (NDAA for FY 2012)?

173 … Yes. Section 1245 of the NDAA for FY 2012 includes an exception that prohibits the President from imposing sanctions “with respect to any person for conducting or facilitating a transaction for the sale of food, medicine, or medical devices to Iran.” … Are there any exceptions to the… Read more

337. Are transactions that were previously authorized under 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) prior to May 17, 2024 or General License (GL) D-2 still authorized under the revised 31 CFR § 560.540?

337 … Yes, transactions that were authorized under 31 CFR § 560.540 of the ITSR as of May 16, 2024 or GL D 2 (as well as its predecessors, GLs D and D-1) continue to be authorized pursuant to the version of 31 CFR § 560.540 revised on May 17, 2024. See FAQs 338–343 and 1110 for additional… Read more

174. What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “owned or controlled by the government of a foreign country,” “food, medicine, and medical devices,” “foreign financial institution,” “Iranian financial institution,” “significantly reduced,” and “whether the price and supply of petroleum and petroleum products produced in countries other than Iran is sufficient”?

174 … "significant financial transaction" The Iranian Financial Sanctions Regulations (IFSR), which implement section 104(c) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), identify factors to be used in determining what is significant (as it relates to… Read more

175. What is the scope of “petroleum products” under the law?

175 … As defined by the U.S. Energy Information Administration (EIA), petroleum products include unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil,… Read more

176. If oil is being provided as payment for an outstanding debt, is such a transfer considered a “financial transaction”?

176 … If a transfer involves a financial institution it would likely be considered a financial transaction . … If oil is being provided as payment for an outstanding debt, is such a transfer considered a “financial …

177. If the Central Bank of Iran (CBI) is involved in providing settlement services for a transaction, or is otherwise acting solely as an intermediary in a transaction between a non-designated Iranian bank and a foreign financial institution, is the foreign financial institution deemed to be engaging in a transaction with the CBI?

177 … Section 1245 targets any significant transactions “with” the CBI; a transaction involving the CBI in an intermediary role would likely be viewed as a transaction “with” the CBI. … If the Central Bank of Iran (CBI) is involved in providing settlement services for a transaction, or is otherwise… Read more

178. Are barter trades involving the Central Bank of Iran (CBI) considered “financial transactions” under Section 1245?

178 … If a transfer involves a financial institution it would likely be considered a financial transaction . … Are barter trades involving the Central Bank of Iran (CBI) considered “financial transactions” under Section …

Frequently Asked Questions

Office of Terrorism and Financial Intelligence