Frequently Asked Questions

U.S. persons are authorized to engage in certain administrative transactions with the Government of Venezuela that are prohibited by E.O. 13884 of August 5, 2019, where such transactions are necessary and ordinarily incident to such persons’ day-to-day operations. General License 35 authorizes U.S… Read more

No.  A specific license from OFAC is not required to initiate or continue U.S. legal proceedings against a person designated or blocked pursuant to the Venezuela Sanctions Regulations, 31 CFR part 591 (VSR), or for a U.S. court, or its personnel, to hear such a case.  Similarly, creditors may file… Read more

As described in the Iranian Financial Sanctions Regulations , the sanctionable activities of a foreign financial institution are: Facilitating the efforts of the Government of Iran (GOI) to acquire or develop Weapons of Mass Destruction (WMD) or delivery systems for WMD or to provide support for… Read more

The list of blocked IRGC affiliates and blocked Iran-linked financial institutions is dynamic and is based on the identity of “designated” persons, which refers both to natural persons (i.e., individuals) and legal persons (such as corporations and other entities). The most recent list of… Read more

The Iranian Financial Sanctions Regulations (IFSR) define “U.S. financial institutions” to include: depository institutions, banks, savings banks, money service businesses, trust companies, insurance companies, securities brokers and dealers, commodities exchanges, clearing corporations, investment… Read more

The Iranian Financial Sanctions Regulations (IFSR) define “ foreign financial institutions ” to include foreign depository institutions, banks, savings banks, money service businesses, trust companies, securities brokers and dealers, commodities exchanges, clearing corporations, investment… Read more

The term “knowingly” as used in the IFSR means that a person has actual knowledge or should have known of specific conduct, a circumstance, or a result. In other words, the IFSR could be implicated if the Treasury Department finds that a foreign financial institution knew or should have known that… Read more

As set out in the IFSR , in determining whether a transaction or financial service is “ significant ,” the Treasury Department may consider: (1) the size, number, frequency, and nature of the transaction(s); (2) the level of awareness of management of the transaction(s) and whether or not the… Read more

A finding by the Treasury Department that a foreign financial institution knowingly engages in one or more of the sanctionable activities is necessary before the Treasury Department can prohibit or impose strict conditions on the opening or maintaining in the United States of correspondent accounts… Read more

As a general matter, the Treasury Department will reach out to foreign financial institutions to inquire about their conduct before making a finding . If the Treasury Department decides to impose strict condition(s), the Treasury Department will issue an order or a regulation that sets out the… Read more