Frequently Asked Questions

314 … Yes. So long as the transaction does not involve a designated individual or entity, banks on the Part 561 List located on OFAC’s website, or otherwise proscribed conduct, such transactions are not sanctionable under U.S. law. Furthermore, there is no requirement under U.S. law that… Read more

266 … Yes. On September 24, 2012, NIOC was identified as an agent or affiliate of Iran’s Islamic Revolutionary Guard Corps (“IRGC”) under section 312 of the TRA , and designated on November 8, 2012, under E.O. 13382 for providing services and support to the IRGC. Accordingly, the Comprehensive Iran… Read more

609 … E.O. 13846 reimposes the sanctions previously contained in subsections 3(a)(ii) and section 5 of E.O. 13645 by authorizing the imposition of correspondent and payable-through account sanctions (subsection 2(a)(i)) of E.O. 13846) and menu-based sanctions (subsection 3(a)(i) of E.O. 13846) for… Read more

610 … E.O. 13846 defines the automotive sector of Iran as the manufacturing or assembling in Iran of light and heavy vehicles including passenger cars, trucks, buses, minibuses, pick-up trucks, and motorcycles, as well as original equipment manufacturing and after-market parts manufacturing… Read more

11 … All U.S. persons must comply with OFAC sanctions, including all U.S. citizens and permanent residents regardless of where they are located, all individuals and entities within the United States, and all U.S. incorporated entities and their foreign branches. Terms such as "U.S. person" and "… Read more

12 … Violations of OFAC-administered sanctions programs may result in civil and, in some cases, criminal penalties. Penalties for violations can be substantial. Civil penalties vary by sanctions program, and the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended by the Federal… Read more

13 … OFAC encourages anyone who may have violated OFAC-administered sanctions programs, or anyone who is aware of potential violations, to disclose the apparent or potential violation to OFAC. Voluntary self-disclosure to OFAC is considered a mitigating factor by OFAC in enforcement actions, and… Read more

14 … Great care should be taken when placing reliance on such materials to ensure that the transactions in question fully conform to the letter and spirit of the published materials and that the materials have not been superseded. … Can I regard previously issued and published opinion letters,… Read more

15 … Yes. OFAC, therefore, strongly encourages parties to exercise due diligence when their business activities may touch on an OFAC-administered program and to contact OFAC if they have any questions about their transactions. … Can OFAC change its previously stated, non-published interpretation or… Read more

468 … If you have questions about the authenticity of an OFAC-issued document that is not publicly posted on OFAC’s website, you may contact OFAC and reference the specific case ID or FAC number that is included on the document. For specific licenses, please visit OFAC’s Licensing Portal and select… Read more