Frequently Asked Questions

621 … Consistent with Section 218 of TRA , section 8 of E.O. 13846 continues in effect the sanctions previously contained in section 4 of E.O. 13628 and expands them to cover activity sanctionable under E.O. 13846 (see FAQ 601 ). This provision prohibits a U.S.-owned or -controlled foreign entity… Read more

640 … This regulatory amendment does two things. First, it amends the ITSR to reflect the re-imposition of ITSR-related sanctions lifted under the JCPOA, including sanctions pursuant to certain sections of E.O. 13846 and the relisting on the SDN List of persons included on the E.O. 13599 List. More… Read more

641 … Yes. Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran involving the Central Bank of Iran are excepted from the relevant sanctions under section 1245(d)(2) of the NDAA 2012 and sections 561.203 and 561.204 of the Iranian Financial Sanctions… Read more

642 … Many U.S. sanctions related to Iran include an exception for countries that have received a SRE under section 1245(d)(4)(D) of the NDAA 2012 (see https://ofac.treasury.gov/faqs/topic/1551  for additional information regarding the implementation of the SRE and sanctionable transactions). To… Read more

643 … Payment of Iran-related insurance or reinsurance claims arising from incidents that occurred prior to November 5, 2018 could create sanctions exposure for non-U.S. persons to the extent such payment involves a person designated in connection with Iran’s proliferation of WMD or support for… Read more

644 … Yes. Under section 560.215 of the ITSR, U.S.-owned or -controlled foreign entities are prohibited from knowingly engaging in any transaction, directly or indirectly, with the Government of Iran or any person subject to the jurisdiction of the Government of Iran that would be prohibited by the… Read more

645 … Following the re-imposition of U.S. sanctions on November 5, 2018, sanctions that had previously been lifted or waived as part of U.S. commitments under the Joint Comprehensive Plan of Action (JCPOA) will come back into effect in their entirety, including sanctions on the provision of… Read more

622 … To the extent a transaction is exempt from the prohibitions of the ITSR , E.O. 13599 , or section 1 or 15 of E.O. 13846 , or is authorized by a general license issued pursuant to these authorities if engaged in by a U.S. person, it would not be prohibited for a U.S.-owned or -controlled… Read more

666 … E.O. 13871 authorizes sanctions with respect to the iron, steel, aluminum, and copper sectors of Iran. Section 1 of E.O. 13871 authorizes blocking sanctions on any person determined by the Secretary of the Treasury, in consultation with the Secretary of State: (i) to be operating in the iron… Read more

667 … E.O. 13871 became effective upon signing. … When does E.O. 13871 become effective? …