Frequently Asked Questions

826 … 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… Read more

593 … 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… Read more

541 … 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… Read more

542 … “ 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

3 … Each OFAC sanctions program is based on different foreign policy and national security goals, so the prohibitions imposed may vary between programs. Many sanctions programs require blocking the property and interests in property of specific individuals and entities and prohibit dealing in such… Read more

4 … Yes. There may be exceptions to sanctions prohibitions. Exceptions may take the form of authorizations, such as general licenses and specific licenses, or exemptions. OFAC issues general licenses in most of its sanctions programs to authorize certain transactions that would otherwise be… Read more

6 … References to relevant statutes, executive orders, regulations, guidance, general licenses, and sanctions actions for each sanctions program may be found in the Sanctions Programs and Country Information page on OFAC’s website. The OFAC Legal Library page on OFAC’s website also contains links… Read more

7 … OFAC issues general licenses to authorize certain transactions that would otherwise be prohibited pursuant to a particular sanctions program. These general licenses are self-executing, meaning they allow persons to engage in certain transactions involving the United States or U.S. persons… Read more

9 … "Blocking" refers to freezing assets or other property. Blocking immediately imposes an across-the-board prohibition against transfers or dealings of any kind with regard to the property. OFAC authorities may require U.S. persons to block all property and interests in property of certain… Read more

10 … OFAC implements, administers, and enforces U.S. sanctions across many jurisdictions. Some of these sanctions are comprehensive in nature and broadly prohibit most transactions involving the particular jurisdiction and may also include blocking restrictions on the government of such… Read more