Frequently Asked Questions

After the 90-day wind-down period ends on August 6, 2018, the following sanctions come into effect, including under provisions of E.O. 13846 and relevant statutory authorities: i. Sanctions on the purchase or acquisition of U.S. dollar banknotes by the GOI (see, e.g., subsection 1(a)(i) of E.O.… Read more

After the 180-day wind-down period ends on November 4, 2018, the following sanctions come into effect, including under provisions of E.O. 13846 and relevant statutory authorities: i. Sanctions on Iran’s port operators, and shipping and shipbuilding sectors, including on the Islamic Republic of Iran… Read more

Section 6 of E.O. 13846 reimposes the sanctions previously contained in section 1 of E.O. 13645 with respect to transactions involving the Iranian rial. FFIs risk correspondent and payable-through account sanctions and blocking sanctions if they, on or after August 7, 2018, (i) knowingly conduct or… Read more

In order for the National Defense Authorization Act's ( NDAA ) significant reduction exception to apply on or after February 6, 2013, the person receiving payment (e.g., the manufacturer or service provider) for goods or services being exported to Iran must be – (i) a citizen, national, or… Read more

No. If funds from the RECIPIENT ACCOUNT or the SPECIAL PURPOSE ACCOUNT are remitted, directly or indirectly, to Iran, or paid to any person that is the GOI , the FFI would be exposed to sanctions. …

The National Defense Authorization Act of Fiscal Year 2012 (NDAA) generally exempts from sanctions sales made under the Humanitarian Exception (i.e., the sale of agricultural commodities, food, medicine, or medical devices from third countries to Iran). Funds deposited in the RECIPIENT ACCOUNT or… Read more

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 agricultural… Read more

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

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

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 relating to… Read more