Frequently Asked Questions

821. What does General License No. 8A (GL 8A) authorize with respect to humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC)?

As a result of the CBI and NIOC's designations pursuant to Executive Order 13224 , as amended (E.O. 13224), U.S. persons are prohibited from engaging in any transaction or dealing in the property or interests in property of the CBI or NIOC under the Global Terrorism Sanctions Regulations, 31 CFR… Read more

822. I'm a U.S. person that relied on general or specific licenses pursuant to 560.530, 560.532, or 560.533 of the ITSR to conduct humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) prior to their designations under E.O. 13224, as amended. Is any further authorization needed to conduct such transactions following the designations of the CBI and NIOC under E.O. 13224?

No. As detailed in FAQ 821 , GL 8A authorizes certain humanitarian-related transactions and activities involving the CBI, NIOC, or any entity in which NIOC owns a 50 percent or greater interest, that would be prohibited by the GTSR or by the ITSR due to the exclusion at section 560.530(d)(5) of the… Read more

823. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions or activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) that U.S. persons would be authorized to engage in under General License No. 8A (GL 8A)?

No. Non-U.S. persons generally do not risk exposure under U.S. secondary sanctions relating to Iran for engaging in the sale of agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in otherwise applicable authorities,… Read more

824. What is the Swiss Humanitarian Trade Arrangement (SHTA)?

On October 25, 2019, the U.S. Departments of State and the Treasury announced a new humanitarian framework to assist foreign governments and foreign financial institutions in establishing payment mechanisms to facilitate humanitarian exports to Iran that are subject to enhanced due diligence. While… Read more

825. How can parties participate in the Swiss Humanitarian Trade Arrangement (SHTA) to export humanitarian goods to Iran?

The SHTA is overseen by Switzerland's State Secretariat for Economic Affairs (SECO) and intended for use by U.S. and non-U.S. persons domiciled in Switzerland. Exporters within Swiss jurisdiction may reach out to SECO at SHTA@seco.admin.ch for further details on requirements and instructions for… Read more

826. What options exist for exporting humanitarian goods to Iran outside the Swiss Humanitarian Trade Arrangement (SHTA)?

Transactions for the sale of agricultural commodities, food, medicine, and medical devices are not required to be processed through the SHTA. See FAQ 637 for guidance setting out existing exceptions to U.S. sanctions for the export of humanitarian goods to Iran. Foreign governments and foreign… Read more

593. If a blocked person holds an equity interest in a foreign entity, and the foreign entity is not itself a blocked person pursuant to OFAC’s fifty percent rule, can the foreign entity be sanctioned under section 10 of SSIDES, as amended by section 228 of CAATSA, and section 5 of UFSA, as amended by section 226 of CAATSA, for paying dividends to the blocked person?

Whether paying dividends to a blocked person who holds an equity interest in the foreign company of less than fifty percent, individually or in the aggregate, would result in OFAC imposing sanctions under these authorities on the payer of the dividends depends on whether OFAC determines that such a… Read more

541. What activities can trigger sanctions on a foreign financial institution (FFI) under section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated into § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR)?

Section 226 of CAATSA amended section 5 of UFSA to make the sanctions in that section, which were previously discretionary, mandatory. This section is implemented in § 589.209 of the URSR. Under § 589.209, FFIs face sanctions if the Secretary of the Treasury determines that they knowingly engage… Read more

542. How does OFAC interpret the following terms as used in section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated into § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR): “significant transaction,” “significant financial transaction,” and “facilitated?”

“ Significant transaction ” and “ significant financial transaction ”– section 589.413 of the URSR states that for purposes of the UFSA prohibitions in § 589.209 , the Secretary of the Treasury will consider the totality of the facts and circumstances when determining whether transactions or… Read more

543. How will U.S. financial institutions and foreign financial institutions (FFIs) know that the Department of the Treasury has imposed prohibitions or strict conditions on FFIs’ correspondent accounts or payable-through accounts in the United States pursuant to section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated in § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR)?

If, pursuant to § 589.209 of the URSR, Treasury decides to impose strict condition(s) on maintaining U.S. correspondent accounts or U.S. payable-through accounts for an FFI, or decides to prohibit the opening or maintaining of U.S. correspondent accounts or U.S. payable-through accounts for an FFI… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence