668 … Persons engaged in transactions that could be sanctioned under E.O. 13871 had a 90-day period after the issuance of E.O. 13871 to wind down those transactions without exposure to sanctions under E.O. 13871. Those persons were advised to take the necessary steps to wind down transactions by… Read more
669 … Yes. E.O. 13871 expands upon existing sanctions under section 1245 of IFCA on the sale, supply, or transfer, directly or indirectly, to or from Iran of certain materials, including raw and semi-finished metals such as aluminum and steel, as described in subsections 1245(a)(l)(B) or (C) of… Read more
670 … Yes. The sanctions authorized under E.O. 13871 do not apply to transactions for the conduct of the official business of the United States Government or the United Nations (including its specialized agencies, programmes, funds, and related organizations) by employees, grantees, or contractors… Read more
671 … The interpretation of “significant transaction or transactions; significant financial services; significant financial transaction,” as described in the correspondent account sanctions in the IFSR, provides that the Department of the Treasury may consider the totality of the facts and… Read more
683 … The interpretation of “significant transaction or transactions,” as described in the ISHR provides that the Department of the Treasury may consider the totality of the facts and circumstances and sets forth a list of broad factors that can play a role in the determination whether transactions… Read more
684 … The term iron sector of Iran means the mining, refining, processing, or manufacturing of iron or iron products in Iran. (31 C.F.R. § 561.336; 31 C.F.R. § 561.317). … What is the definition of the “iron sector of …
685 … The term steel sector of Iran means the iron-ore smelting, ferrous-scrap melting, refining, processing, or manufacturing of steel or steel products in Iran. (31 C.F.R. § 561.337; 31 C.F.R. § 562.318). … What is the definition of the “steel sector of …
623 … No. Section 8 of E.O. 13846 continues in effect the prohibition previously contained in section 4 of E.O. 13628, which — consistent with subsection 218(d) of the TRA — provided that civil penalties would not apply if a U.S. person that owns or controls the foreign entity divested or… Read more
565 … Answer: No. … For purposes of E.O. 13827 "Taking Additional Steps to Deal with the Situation in Venezuela" of March 19, 2018, is Venezuela’s traditional fiat currency, bolivar fuerte, considered a “digital currency, digital coin, or digital token” that was issued by, for, or on behalf of the… Read more
566 … Absent authorization from OFAC, U.S. persons are prohibited from engaging in transactions related to, providing financing for, and otherwise dealing in any “digital currency, digital coin, or digital token” that was issued by, for, or on behalf of the Government of Venezuela on or after… Read more