Frequently Asked Questions

314. Can an exporter of agricultural commodities, food, medicine, or medical devices get paid out of a Central Bank of Iran (CBI) account at a foreign financial institution (FFI) in a country with a significant reduction exception, even though the exporter is located in a third-country? Can the third-country exporter’s bank handle this transaction?

314 … Yes. So long as the transaction does not involve a designated individual or entity, banks on the Part 561 List located on OFAC’s website, or otherwise proscribed conduct, such transactions are not sanctionable under U.S. law. Furthermore, there is no requirement under U.S. law that… Read more

266. Does the November 8, 2012 designation of National Iranian Oil Company (NIOC) under E.O. 13382 impact the scope of permissible transactions by foreign financial institutions (FFIs) in significantly reducing countries?

266 … Yes. On September 24, 2012, NIOC was identified as an agent or affiliate of Iran’s Islamic Revolutionary Guard Corps (“IRGC”) under section 312 of the TRA , and designated on November 8, 2012, under E.O. 13382 for providing services and support to the IRGC. Accordingly, the Comprehensive Iran… Read more

609. What does E.O. 13846 do with respect to the sanctions on Iran’s automotive sector?

609 … E.O. 13846 reimposes the sanctions previously contained in subsections 3(a)(ii) and section 5 of E.O. 13645 by authorizing the imposition of correspondent and payable-through account sanctions (subsection 2(a)(i)) of E.O. 13846) and menu-based sanctions (subsection 3(a)(i) of E.O. 13846) for… Read more

610. What is considered Iran’s automotive sector for purposes of E.O. 13846?

610 … E.O. 13846 defines the automotive sector of Iran as the manufacturing or assembling in Iran of light and heavy vehicles including passenger cars, trucks, buses, minibuses, pick-up trucks, and motorcycles, as well as original equipment manufacturing and after-market parts manufacturing… Read more

504. I understand that travel to Russia involves clearing Russian border control, which is part of the FSB. Do I need a license from OFAC to travel to Russia, or to clear Russian customs?

504 … No, the sanctions on the FSB do not apply to transactions by U.S. persons that are ordinarily incident to travel to or from Russia, including those transactions required to enter into or exit the country (i.e., complying with Russian border control requirements). … I understand that travel to… Read more

129. Can I make a private donation to a charity that is delivering humanitarian assistance in Somalia?

129 … Yes. Please visit USAID’s website for more information about how you can help. … Can I make a private donation to a charity that is delivering humanitarian assistance in Somalia? …

130. Can my organization provide humanitarian assistance in Somalia?

130 … Yes, non-governmental organizations may provide humanitarian assistance in Somalia without the need for a license from OFAC. Organizations considering entering Somali territory to conduct assistance operations should be aware that areas of Somalia are extremely unstable and dangerous, and… Read more

131. What if, in delivering humanitarian assistance, my organization unintentionally provides food or medicine to members of al-Shabaab?

131 … Due to the dangerous and highly unstable environment combined with urgent humanitarian needs in south and central Somalia, some food and/or medicine delivered in these areas may end up in the hands of al-Shabaab members. Such incidental benefits are not a focus for OFAC sanctions enforcement… Read more

132. What if, in delivering humanitarian assistance, my organization unintentionally provides cash to members of al-Shabaab?

132 … U.S. persons should be extremely cautious in making cash payments in areas under the control of al-Shabaab. Al-Shabaab has, in the past, demanded “taxes” and “access” payments from assistance organizations. To the extent that such a payment is made unintentionally by an organization in the… Read more

133. I have heard that certain U.S. humanitarian assistance organizations are exempted from the prohibition on making certain cash payments to al-Shabaab. Is that correct?

133 … Under the current extreme circumstances on the ground, the Department of State and USAID and their contractors and grantees are authorized to engage in certain transactions in the conduct of their official assistance activities in Somalia, under rigorous controls aimed at preventing diversion… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence