Frequently Asked Questions

300. For purposes of sanctions under section 1245, how will I know which sectors are controlled by Iran’s Islamic Revolutionary Guard Corps?

300 … Pursuant to delegated authority, the Secretary of State issues periodic reports pursuant to section 1245(e) of IFCA with respect to which sectors of the Iranian economy are controlled directly or indirectly by Iran’s Islamic Revolutionary Guard Corps (IRGC). Given the opaque business… Read more

301. How will the determination be made as to whether materials are used in a manner that would make them subject to sanctions under section 1245 of IFCA?

301 … A FFI , prior to conducting or facilitating a significant financial transaction for the sale, supply, or transfer to or from Iran of the materials listed in 1245(d) – as described in part in Q&A 298 – will need to undertake due diligence to ensure that the transaction does not involve the… Read more

302. Are there any exceptions to section 1245 of IFCA?

302 … A person will not be subject to sanctions under section 1245 of IFCA if a determination is made by the Department of the Treasury or the Department of State, as appropriate, that the person has established and enforced official policies, procedures, and controls to ensure that the person does… Read more

303. Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under IFCA's section 1246(a)(1)?

303 … A number of insurance activities are subject to sanctions under IFCA , including knowingly providing insurance, reinsurance, or underwriting services to or for Iranian persons on the SDN List to or for any person designated in connection with Iran’s support for international terrorism or WMD… Read more

348. May U.S. persons employ agents in Iran to facilitate sales, create or fund a physical sales presence on the ground in Iran, or utilize Iranian commercial marketing services in furtherance of exports authorized under 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?

348 … No. Section 560.540 of the ITSR does not authorize the employment of persons in Iran to facilitate sales, the maintenance of a physical sales presence in Iran, or the utilization of Iranian marketing services. However, the exportation of certain copy-ready advertising materials is exempt… Read more

304. Are there exceptions to insuring, reinsuring, or underwriting sanctioned activities?

304 … Yes. IFCA includes the following exceptions to insuring, reinsuring, or underwriting sanctioned activities. a. Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran or for the provision of humanitarian assistance to the people of Iran can be insured… Read more

417. Are payments or the facilitation of payments not involving U.S. persons to Iranian civil aviation authorities for overflights of Iran or landing in Iran by aircraft that are owned by a non-U.S. person and registered outside the United States sanctionable under U.S. law?

417 … No. Provided that the relevant transactions do not involve the U.S. financial system or persons on the Specially Designated Nationals and Blocked Persons List ( SDN List ), payments of charges for services rendered by the Government of Iran in connection with the overflight of Iran or… Read more

1189. What additional authorizations did Treasury issue on August 23, 2024 with respect to certain diamonds and diamond jewelry prohibited by Executive Order (E.O.) 14068?

1189 … Treasury issued two general licenses (GLs), GL 103 and GL 104, authorizing certain transactions with respect to certain diamonds and diamond jewelry that would otherwise be prohibited by E.O. 14068 in “Prohibitions Related to Imports of Certain Categories of Diamonds” (the “ Diamonds… Read more

1190. Do U.S. sanctions target persons for engaging in political speech, religious practice, or other constitutionally protected activities?

1190 … OFAC does not sanction persons for their engagement in activities subject to U.S. constitutional protection, such as protected speech or religious practice or for their religious beliefs; nor do U.S. persons violate OFAC sanctions for engaging in such constitutionally protected activity.… Read more

1191. On September 12, 2024, OFAC designated Ly Yong Phat (Ly), L.Y.P. Group Co., LTD (L.Y.P. Group), and the following entities owned by L.Y.P. Group under the Global Magnitsky sanctions authority: O-Smach Resort, Garden City Hotel, Koh Kong Resort, and Phnom Penh Hotel. Can I continue to engage in transactions or other dealings with other entities owned by Ly or L.Y.P. Group that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

1191 … Yes. Although transactions or other dealings involving Ly and L.Y.P. Group are prohibited as a result of OFAC's designation, OFAC concurrently issued Global Magnitsky General License (GL) 8 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ly or the… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence