Frequently Asked Questions

813. As a member of the art community, what are my compliance obligations with respect to Executive Order 13224, as amended?

U.S. persons (including galleries, museums, private art collectors, auction companies, and others that conduct or facilitate transactions involving artwork) must ensure that they do not engage in transactions with persons listed as Specially Designated Global Terrorists (SDGTs) on OFAC’s SDN List… Read more

814. I am currently in possession of artwork in which a Specially Designated Global Terrorist (SDGT) has an interest. What should I do?

Once it has been determined that you or your institution is holding or is in possession of artwork that is the property of an SDGT or a person otherwise blocked pursuant to E.O. 13224, or in which such a person has an interest, you or your institution must ensure that access to that artwork is… Read more

447. What will significant malicious “cyber-enabled” activities mean for the purposes of Executive Order (E.O.) 13694?

We anticipate that regulations to be promulgated will define “cyber-enabled” activities to include any act that is primarily accomplished through or facilitated by computers or other electronic devices. For purposes of E.O. 13694 , malicious cyber-enabled activities include deliberate activities… Read more

448. I conduct cyber-related activities for legitimate educational, network defense, or research purposes only. Am I vulnerable to the application of sanctions under this authority for these activities?

The measures in this order are directed against significant malicious cyber-enabled activities that have the purpose or effect of causing specific enumerated harms, and are not designed to prevent or interfere with legitimate cyber-enabled academic, business, or non-profit activities. The U.S.… Read more

449. I administer a network for my employer and I regularly deny access to certain services and systems (e.g., retail websites, social media platforms) in order to ensure the performance of the network for authorized business activities. Could I or my employer be sanctioned for this?

The measures in this order are designed to address the threat posed by individuals and entities engaged in significant malicious cyber-enabled activities that have the purpose or effect of causing specific enumerated harms. These measures are not designed to prevent or interfere with legitimate… Read more

450. Will Treasury impose sanctions on persons whose personal computers (or other networked electronic devices) are, without their knowledge or consent, used in malicious cyber-enabled activities (e.g., in denial-of-service attacks against U.S. financial institutions)?

No. These sanctions are designed to target those actors whose malicious cyber-enabled conduct is reasonably likely to result in, or have materially contributed to, a significant threat to the national security, foreign policy, or economic health or financial stability of the United States. These… Read more

118. I have a client that is in Iran to visit a relative. Do I need to restrict the account?

No. As long as you are satisfied that the client is not ordinarily resident in Iran, then the account does not need to be restricted. See FAQ 37 . …

54. I have an account with a W-8 showing an address in Iran. Is the account automatically restricted?

In the absence of information proving to your satisfaction that the account holder is not in Iran, you should consider the account restricted based on the W-8 filing. See FAQ 37 . …

451. How do financial sanctions relate to existing legal authorities in this context?

The United States’ whole-of-government strategy to combat cyber threats draws from a broad range of tools and authorities to respond to the growing and evolving threat posed by malicious cyber actors. Similar to our approach to global threats from terrorists, narcotics traffickers, and… Read more

533. What are the requirements of CAATSA section 105 related to the imposition of sanctions on the IRGC, and how are those requirements being implemented?

On August 2, 2017, the President signed into law the “Countering America’s Adversaries Through Sanctions Act” (Public Law 115-44) ( CAATSA ), which, among other things, imposes new sanctions on Iran. Section 105 of CAATSA requires the imposition of sanctions applicable pursuant to the global… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence