Frequently Asked Questions

828. I want to help with the humanitarian response to public health concerns, including the Coronavirus Disease 2019 (COVID-19) outbreak, in Iran. What can I do to help while remaining compliant with U.S. sanctions?

828 … There are a number of ways consistent with U.S. sanctions to provide humanitarian goods or assistance to the Iranian people in response to public health concerns in Iran, including the COVID-19 outbreak. The making of humanitarian donations to recipients in Iran from the United States or by… Read more

289. How will the following Iran Freedom and Counter-Proliferation Act (IFCA) terms be interpreted: “Iran,” “knowingly,” “significant,” and “transfer”?

289 … As a general matter, we intend to rely, where applicable, on definitions of terms previously included in Treasury regulations. “Iran” The Iranian Financial Sanctions Regulations ( 31 CFR part 561 ) (IFSR) define “Iran” as the Government of Iran and the territory of Iran and any other… Read more

68. If a policyholder becomes a Specially Designated National (SDN) or blocked person after policy issuance, can the insurer notify the policyholder that the policy is now "blocked"?

68 … Yes. The insurer may notify the policyholder that the policy is blocked without obtaining a specific license from OFAC. Date Updated: November 13, 2024 … If a policyholder becomes a Specially Designated National (SDN) or blocked person after policy issuance, can the insurer notify the… Read more

69. When notifying a policyholder that their policy is "blocked" due to OFAC sanctions, may the insurer also instruct the policyholder not to send further premium payments or that the insurer will not accept additional premium payments under this account?

69 … The insurer may instruct the policyholder that in accordance with applicable U.S. laws and regulations administered by OFAC, the insurer must place any subsequent premium payments into a blocked account. For funds, such as unearned premium payments, that are blocked in addition to the policy,… 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

791. Are Cuban nationals located outside of Cuba still considered blocked?

791 … Yes, but any individual Cuban national who can establish that he or she has taken up permanent residence outside of Cuba and otherwise meets the requirements set forth in 31 CFR § 515.505 is generally licensed as an unblocked national. Additionally all persons subject to U.S. jurisdiction are… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence