Frequently Asked Questions

118 … No. As long as you are satisfied that the client is not ordinarily resident in Iran, then the account does not need to be restricted. See FAQ 37 .  … I have a client that is in Iran to visit a relative. Do I need to restrict the …

54 … In the absence of information proving to your satisfaction that the account holder is not in Iran, you should consider the account restricted based on the W-8 filing. See FAQ 37 . … I have an account with a W-8 showing an address in Iran. Is the account automatically …

451 … The United States’ whole-of-government strategy to combat cyber threats draws from a broad range of tools and authorities to respond to the growing and evolving threat posed by malicious cyber actors. Similar to our approach to global threats from terrorists, narcotics traffickers, and… Read more

533 … On August 2, 2017, the President signed into law the “Countering America’s Adversaries Through Sanctions Act” (Public Law 115-44) ( CAATSA ), which, among other things, imposes new sanctions on Iran. Section 105 of CAATSA requires the imposition of sanctions applicable pursuant to the global… Read more

489 … No. This authority does not target American whistleblower activity or constitutionally protected activity. The E.O. defines misappropriation to be the “taking or obtaining by improper means, without permission or consent, or under false pretenses.” Importantly, to be eligible for sanctions… Read more

534 … Before October 13, 2017, the IRGC was blocked under Executive Order 13382 (relating to WMD proliferation), 13553 (relating to Iranian human rights abuses), and 13606 (relating to Iranian and Syrian human rights abuses via information technology), and persons who engaged in certain activity… Read more

260 … A SPECIAL PURPOSE ACCOUNT is an account set up with conditions and safeguards that require the account to be used only for bilateral trade in goods or services between Iran and the country with primary jurisdiction over the FFI , and for sales made under the Humanitarian Exception (see FAQ… Read more

549 … In light of the tragic earthquake in Iran, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) would like to highlight some of the ways in which Americans can provide humanitarian assistance to the Iranian people, consistent with the Iran-related sanctions administered by… Read more

261 … Transfers on or after February 6, 2013, of funds deposited in the RECIPIENT ACCOUNT or the SPECIAL PURPOSE ACCOUNT to third-country financial institutions are not covered by the National Defense Authorization Act's ( NDAA ) significant reduction exception , and create exposure to sanctions… Read more

597 … In accordance with his May 8, 2018 decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA) and to reimpose all of the U.S. sanctions lifted or waived in connection with the JCPOA, the President issued E.O. 13846 on August 6, 2018 to reimpose… Read more