Frequently Asked Questions

844 … No.  Non-U.S. persons generally do not risk exposure to U.S. secondary sanctions for engaging in the sale of agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in  E.O. 13902 and other applicable sanctions authorities… Read more

845 … Yes.  Non-U.S. persons engaged in transactions and activities involving the Iranian financial sector or any Iranian FI sanctioned pursuant to E.O. 13902 that were not previously sanctionable will have 45 days to conclude these activities without risking exposure to sanctions.  The 45-day wind… Read more

846 … Waivers issued by the Department of State (State) and exceptions set forth in IFCA remain valid and activities conducted under them involving Iranian FIs are not sanctionable during the wind-down period described in FAQ 845 .  Persons engaged in transactions or activities involving the… Read more

847 … For purposes of E.O. 13902, OFAC would not generally view transactions or activities by non-U.S. persons to be sanctionable if they are consistent with activities that would be permissible if conducted by U.S. persons.  As noted in FAQ 842 , General License (GL) L authorizes U.S. persons to… Read more

630 … The wind-down period has ended and the United States intends to fully enforce the sanctions that have come back into effect. The provision or delivery of goods or services and/or the extension of additional loans or credits to an Iranian counterparty after November 4, 2018 — even pursuant to… Read more

631 … In the event that a non-U.S., non-Iranian person is owed payment after the conclusion of the wind-down period on August 6, 2018, or November 4, 2018, as applicable, for goods or services fully provided or delivered to an Iranian counterparty prior to August 6, 2018, or November 4, 2018, as… Read more

632 … OFAC encourages non-U.S., non-Iranian persons to rely on the guidance provided in FAQs 631 and 634. Non-U.S., non-Iranian persons can seek guidance from OFAC or the State Department, as appropriate, prior to the receipt of payment, if they would like to confirm that the payments would meet… Read more

633 … OFAC looks to the industry standard to determine whether particular goods or services are considered fully provided or delivered prior to the expiration of the relevant wind-down period. As a general matter, goods or services will be considered fully provided or delivered when the party… Read more

598 … E.O. 13846 reimposes relevant blocking sanctions, correspondent and payable-through account sanctions, and menu-based sanctions previously provided for in E.O.s 13574, 13590, 13622, and 13645, which were revoked by E.O. 13716, and continues in effect sanctions authorities provided for in E.O.… Read more

690 … The terms copper and copper products mean any raw, semi-fabricated, fabricated, or finished form of copper or copper alloy of all grades, sizes, and thicknesses, including in the following forms: ores and concentrates; copper mattes; cement copper (precipitated copper); refined, unrefined,… Read more