Frequently Asked Questions

818. Is there a wind-down period for transactions involving Rosneft Trading S.A. or TNK Trading International S.A.?

818 … OFAC issued General License(GL) 36A, which authorizes U.S. persons to engage in certain activities prohibited by E.O. 13850 necessary for the wind down of transactions involving Rosneft Trading S.A. or TNK Trading International S.A., or any entity in which Rosneft Trading S.A. or TNK Trading… Read more

819. Is the June 21, 2019 amendment to the Office of Foreign Assets Control (OFAC)'s Reporting, Procedures and Penalties Regulations in effect? Am I required to comply with all requirements of the amended regulations?

819 … Yes, effective June 21, 2019, OFAC amended the Reporting, Procedures and Penalties Regulations, 31 CFR part 501 (RPPR) , to provide updated instructions and incorporate new requirements for parties filing reports on blocked property, unblocked property, or rejected transactions. In addition,… Read more

658. Can U.S. persons purchase, or engage in other transactions including swaps and non-cash transactions involving the purchase or exchange of, petroleum and petroleum products, if Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest is not directly involved in the transaction?

658 … After 12:01 a.m. eastern daylight time, April 28, 2019, as described in Venezuela-related General License 7 and General License 12, any transactions (including swaps and non-cash transactions) involving the purchase or exchange of petroleum or petroleum products in which PdVSA or any entity… Read more

656. Can U.S. persons in Venezuela purchase gasoline or other refined petroleum products from Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest?

656 … Yes. Venezuela-related General License 10 authorizes U.S. persons in Venezuela to purchase refined petroleum products, including gasoline, for personal, commercial, or humanitarian uses from PdVSA, or any entity in which it owns, directly or indirectly, a 50 percent or greater interest.… Read more

318. Does the GL for medical devices authorize the exportation or reexportation of all medical devices?

318 … No. The GL for medical devices appearing at section 560.530 (a)(3)(i) of the Iranian Transactions and Sanctions Regulations ( ITSR ) authorizes covered persons, as defined in section 560.530(e)(4), to export or reexport to Iran medical devices as defined in section 560.530(e)(3) of the ITSR,… Read more

319. Does the GL for medical devices authorize the exportation or reexportation of these items to all entities in Iran?

319 … No. While the GL under section 560.530 (a)(3)(i) of the Iranian Transactions and Sanctions Regulations ( ITSR ) authorizes exports or reexports of certain medical devices to most entities in Iran, it does not authorize exports or reexports to military, intelligence, or law enforcement… Read more

361. What items and persons are excluded from the agricultural commodities general license in the Iranian Transactions and Sanctions Regulations (ITSR)?

361 … The specified items excluded from the scope of the agricultural commodities general license are: castor beans, castor bean seeds, certified pathogen-free eggs (unfertilized or fertilized), dried egg albumin, live animals (excluding live cattle, shrimp, and shrimp eggs), embryos (excluding… Read more

362. Is the exportation or reexportation of non-U.S.-origin agricultural commodities, medicine, or medical devices by a U.S. person to Iran authorized?

362 … Yes. The definitions of the terms “agricultural commodities,” “medicine,” and “medical device” used in the relevant general licenses in the ITSR include, in the case of items subject to Commerce's Export Administration Regulations (EAR), items that are designated as EAR99 and, in the case of… Read more

363. Is the exportation or reexportation by non-U.S. persons of agricultural commodities, medicine, or medical devices that are subject to the Export Administration Regulations (EAR) to Iran authorized?

363 … Yes. A non-U.S. person may export or reexport agricultural commodities, medicine, or medical devices to Iran under the relevant general licenses in the ITSR , provided that the items are subject to Commerce's Export Administration Regulations (EAR); and all conditions of the relevant general… Read more

364. Who can apply for a specific license if an export or reexport to Iran is not authorized by general license?

364 … If an export or reexport is not authorized by general license, any U.S. person, or non-U.S. person exporting items subject to Commerce's Export Administration Regulations (EAR); and designated as EAR99, wherever located, or U.S.-owned or -controlled foreign entity may apply for a specific… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence