Frequently Asked Questions

313 … IFCA was signed into law on January 2, 2013, as a part of the National Defense Authorization Act for Fiscal Year 2013, and provides for several new sanctions related to Iran. IFCA authorizes broad sanctions on: certain activities related to Iran’s energy, shipping, and shipbuilding sectors;… Read more

290 … There is no general exception for payments, sales, deliveries, or transfers arising out of contracts entered into prior to July 1, 2013, on or after which date certain activities become sanctionable under the  Iran Freedom and Counter-Proliferation Act of 2012 (IFCA). The assessment of… Read more

292 … IFCA generally excepts from sanctions transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran, as set out in more detail in Q&As 297 and 304 . … What are the implications of IFCA on the provision of humanitarian goods to the people of …

293 … We anticipate that regulations to be promulgated will define “energy sector of Iran” to include activities involving the exploration, extraction, production, refinement, or liquefaction of petroleum, natural gas, or petroleum products in Iran. (See also discussion of activities involving… Read more

229 … No. You may send U.S.-origin food or medicine to Syria without a specific license from OFAC. The Department of Commerce, Bureau of Industry and Security (“BIS”), which maintains jurisdiction over the export of most items to Syria, does not require a license for the export of U.S.-origin food… Read more

294 … Persons determined to be part of Iran’s energy, shipping, or shipbuilding sectors, or a port operator in Iran for purposes of IFCA section 1244(c) will be identified as such on the SDN List . Knowingly providing certain significant support to persons determined to be part of Iran’s energy,… Read more

295 … We anticipate that regulations to be promulgated will define goods and services used in connection with Iran’s energy, shipping and shipbuilding sectors to include: a. Energy Sector: In the case of Iran’s energy sector, goods or services that contribute to, Iran’s ability to develop its… Read more

227 … Yes.  Pursuant to 31 CFR § 542.512 , U.S. persons may continue to send noncommercial, personal remittances to friends or family in Syria, provided the transfer is not by, to, or through the Government of Syria or any other person whose property and interests in property are blocked.   Syria… Read more

296 … If a non-Iranian vessel is transporting non-sanctionable goods to or from Iran, the bunkering of that non-Iranian vessel in a country other than Iran — and related payments for these bunkering services — will not be subject to sanctions, only if (1) the transaction either does not involve U.S… Read more

205 … U.S. persons may donate funds to and raise funds on behalf of U.S. and third-country NGOs that engage in authorized activities in Syria (please see § 542.516 of the Syrian Sanctions Regulations for the full list of authorized activities).  U.S. persons can also donate humanitarian goods like… Read more