Frequently Asked Questions

590. I am a foreign person that seeks to pay GAZ Group or another entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest for goods or services connected with activities authorized by General License (GL) 15L. Am I required to deposit payment into a blocked account at a U.S. financial institution in order for my payment not to be considered “significant” for purposes of section 10 of SSIDES, as amended by section 228 of CAATSA, or section 5 of UFSA, as amended by section 226 of CAATSA?

590 … No. U.S. persons may engage in activities authorized by GL 15L that occur on or after May 22, 2018, except for activities involving blocked persons other than GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) without making associated… Read more

591. I am a U.S. person that seeks to supply goods to GAZ Group. Am I permitted to export those goods from the United States to GAZ Group pursuant to General License (GL) 15L?

591 … GL 15L authorizes transactions and activities that are ordinarily incident and necessary to the wind down of transactions involving GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest), including exports. Any exports to GAZ Group must be… Read more

592. Does General License (GL) 15L authorize U.S. persons to receive regularly scheduled payments of principal and interest from GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest)? Does GL 15L authorize U.S. persons to receive accelerated payments or voluntary prepayment pursuant to the terms of such loan or bond?

592 … Yes, GL 15L authorizes U.S. persons to receive regularly scheduled payments of principal and interest from GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) only to the extent such transactions are ordinarily incident and necessary to… Read more

620. What are the definitions of "petroleum products" and "petrochemical products"?

620 … The term "petroleum products," as defined in section 16(o) of E.O. 13846 , includes unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical… Read more

634. Can I, as a non-U.S., non-Iranian person, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period pursuant to contracts entered into prior to May 8, 2018?

634 … Yes, subject to the conditions set out below and in FAQ 631 above, non-U.S., non-Iranian persons may receive payment after the end of the relevant wind-down period for goods or services fully provided or delivered to an Iranian counterparty prior to expiration of the relevant wind-down period… Read more

635. Can I, as a U.S. person or U.S.-owned or -controlled foreign entity, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period under an OFAC wind-down authorization and pursuant to a contract entered into prior to May 8, 2018?

635 … The wind-down authorizations allow U.S. persons and U.S.-owned or -controlled foreign entities to receive payments for activities conducted pursuant to such wind-down authorizations only during their validity periods. For example, a U.S.-owned or -controlled foreign entity may receive payment… Read more

636. Can I receive payment for activities undertaken during the wind-down period if the payment involves a person that has been added to the SDN List, including a person that was previously on the List of Persons Blocked Solely Pursuant to E.O. 13599 (the “E.O. 13599 List”) but is now designated under another authority?

636 … The United States intends to fully enforce the sanctions that apply to persons that were previously on the E.O. 13599 List but that are now designated under another authority. U.S. persons and U.S.-owned or -controlled foreign entities generally would require an OFAC authorization to receive… Read more

637. Is it sanctionable for non-U.S., non-Iranian persons to engage in transactions related to the provision of humanitarian and consumer goods to Iran?

637 … The United States maintains broad authorizations and exceptions under U.S. sanctions that allow for the sale of agricultural commodities, food, medicine, and medical devices to Iran from the United States or by U.S. persons or U.S.-owned or -controlled foreign entities. U.S. sanctions laws… Read more

638. What happened to the E.O. 13599 List?

638 … The E.O. 13599 List was created to clarify that, regardless of their removal from the SDN List on January 16, 2016, persons that OFAC had previously identified as meeting the definition of the terms “Government of Iran” or “Iranian financial institution” still met those definitions and… Read more

639. Why are some persons that had been blocked solely pursuant to E.O. 13599 now designated pursuant to other authorities, such as E.O. 13224 and E.O. 13382?

639 … OFAC designated multiple Iranian financial institutions and other persons previously blocked solely pursuant to E.O. 13599 under E.O. 13224 (relating to counterterrorism), E.O. 13382 (relating to WMD proliferation), and E.O. 13553 (relating to serious human rights abuses by the Government of… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence