Frequently Asked Questions

E.O. 13846 does not make sanctionable the export of finished vehicles to Iran if no further assembly or manufacturing is required. As such, exporting fully assembled and finished vehicles to Iran for sale would not be sanctionable, so long as the transaction is consistent with U.S. sanctions,… Read more

Goods or services for the maintenance of finished vehicles exported to Iran would generally not be considered “significant goods or services used in connection with the automotive sector of Iran” for the purposes of E.O. 13846 , and the provision of such goods or services would generally not be… Read more

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; the… Read more

Pursuant to section 5(a) of the HKAA , the Secretary of State submitted a report (“Section 5(a) Report”) on October 14, 2020 to the appropriate congressional committees and leadership identifying foreign persons that the Secretary of State, in consultation with the Secretary of the Treasury,… Read more

Pursuant to section 5(d)(2) of the HKAA , an FFI may be excluded from the Section 5(b) Report or an update to that report under section 5(e) of the HKAA, or may be removed from the Section 5(b) Report or an update to that report prior to the imposition of sanctions under section 7(a), if the… Read more

For purposes of implementing section 5(b) of the HKAA , the Secretary of the Treasury may consider the totality of the facts and circumstances when determining whether transactions are “significant.”  As a general matter, the Treasury Department may consider some or all of the following factors in… Read more

Section 2 of HKAA defines these terms as follows, which OFAC intends to incorporate into relevant regulations: “financial institution” – the term “financial institution” is defined to have the same meaning as a financial institution specified in section 5312(a)(2) of title 31, United States Code… Read more

On October 27, 2020, OFAC issued an amendment to the CACR, effective November 26, 2020, to remove from the scope of certain remittance-related general authorizations any transactions involving entities or subentities identified on the State Department’s Cuba Restricted List . Specifically, the… Read more

General licenses issued under the Iranian Transactions and Sanctions Regulations (ITSR) authorize certain U.S. academic institutions and other U.S. persons to provide certain services and software to Iranian students.  These general licenses include: General License G (GL G) authorizes accredited… Read more

On November 30, 2020, OFAC designated CEIEC pursuant to Executive Order (E.O.) 13692 for its role in undermining democracy in Venezuela.  Concurrent with this action, OFAC issued Venezuela General License (GL) 38 (“Authorizing the Wind Down of Transactions Involving CEIEC”).  GL 38 authorizes U.S.… Read more