Frequently Asked Questions

The best and most reliable approach for issuing policies with global risk coverage without violating U.S. sanctions law is to include a clause ensuring there is no coverage for risks that violate U.S. sanctions law. The exact wording of such clauses may vary depending on the type of policy (e.g.,… Read more

OFAC recognizes that U.S. insurers and reinsurers often compete in international markets where non-U.S. insurers are willing and able to issue global insurance policies without an exclusion that applies to U.S. sanctions, or where such clauses may be prohibited under local law. In cases where an… Read more

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 Republic,… Read more

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 facilitating… Read more

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 jurisdiction… Read more

U.S.-owned or -controlled entities in third countries may provide goods and services to a Cuban national located outside of Cuba, provided that the transaction does not involve a commercial exportation, directly or indirectly, of goods or services to or from Cuba. For a complete description of what… Read more

Yes. Persons subject to U.S. jurisdiction may provide financial services to a Cuban national located outside of Cuba who is an individual, provided that the transaction does not involve a commercial exportation, directly or indirectly, of goods or services to or from Cuba. Additionally, banking… Read more

Section 515.590 of the CACR authorizes the provision of grants, scholarships, or awards to a Cuban national, including a Cuban state-owned entity provided that entity is not included on the State Department’s Cuba Restricted List , and as long as any such grant, scholarship, or award is related to… Read more

Section 515.523 of the Cuban Assets Control Regulations authorizes all transactions incident to the administration and distribution of the assets of a blocked estate of a decedent. All property distributed pursuant to 31 CFR § 515.523 is unblocked, provided that neither Cuba nor a Cuban national (… Read more

Among other things, the provision for microfinancing projects in section 515.575 of the Cuban Assets Control Regulations (CACR) authorizes the provision of certain financial services to unemployed, underemployed, and low-income Cubans who have little or no access to conventional banks or comparable… Read more