Frequently Asked Questions

Persons designated under the GHRAVITY E.O. appear on the publicly available Specially Designated Nationals List ( SDN list ) bearing the [HRIT] tag. U.S. persons are obligated to block property involving the persons bearing the tag [HRIT] on the SDN list, unless the transaction is exempt or… Read more

This E.O. does not generally prohibit transactions involving persons that do business with Iran or Syria, unless the person has been designated pursuant to this order. You should consult with the Department of Commerce’s Bureau of Industry and Security (BIS) regarding exports to companies that do… Read more

The measures in this order are designed primarily to address the need to prevent entities located in whole or in part in Iran and Syria from facilitating or committing serious human rights abuses. These measures are not designed to prevent the provision of information and communications technology… Read more

Yes. For more information regarding exports of goods or technology to persons blocked under the GHRAVITY E.O. please contact OFAC or BIS. …

If you require assistance interpreting the authorizations contained in 31 CFR § 560.540 and how they apply to your situation, please contact OFAC’s Compliance hotline or submit a request for interpretive guidance at the OFAC License Application Page . Date Updated: May 16, …

Yes.  For purposes of the authorities administered by OFAC, 31 CFR § 560.540 authorizes the exportation, reexportation, or provision of certain hardware and software subject to the EAR by non-U.S. persons outside the United States.  See 31 CFR § 560.540(a)(2)(i) and (a)(3).  For example, a non-U.S… Read more

Yes.  Section 560.540 of the ITSR continues to authorize the exportation, reexportation, or provision to Iran by U.S. persons located outside of the United States of certain specified hardware and software items that are not subject to the EAR .  See 31 CFR § 560.540(a)(2)(ii), (a)(3)(ii) and (iii… Read more

Yes.  Section 560.540 of the ITSR authorizes the exportation, reexportation, or provision to Iran and the importation into the United States by an individual entering the United States directly or indirectly from Iran, of hardware and software authorized by paragraphs 31 CFR § 560.540(a) (2) or (a… Read more

Depository institutions, as defined in 31 CFR § 515.333 , which include certain financial institutions other than banks, are permitted to open correspondent accounts at banks in Cuba. See 31 CFR § 515.584(a) …

No. U.S. depository institutions are permitted to open correspondent accounts at Cuban banks located in Cuba and in third countries, and at foreign banks located in Cuba, but Cuban banks are not generally licensed to open such accounts at U.S. banks. See note to 31 CFR § 515.584(a) …