Frequently Asked Questions

449. I administer a network for my employer and I regularly deny access to certain services and systems (e.g., retail websites, social media platforms) in order to ensure the performance of the network for authorized business activities. Could I or my employer be sanctioned for this?

The measures in this order are designed to address the threat posed by individuals and entities engaged in significant malicious cyber-enabled activities that have the purpose or effect of causing specific enumerated harms. These measures are not designed to prevent or interfere with legitimate… Read more

450. Will Treasury impose sanctions on persons whose personal computers (or other networked electronic devices) are, without their knowledge or consent, used in malicious cyber-enabled activities (e.g., in denial-of-service attacks against U.S. financial institutions)?

No. These sanctions are designed to target those actors whose malicious cyber-enabled conduct is reasonably likely to result in, or have materially contributed to, a significant threat to the national security, foreign policy, or economic health or financial stability of the United States. These… Read more

118. I have a client that is in Iran to visit a relative. Do I need to restrict the account?

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 . …

54. I have an account with a W-8 showing an address in Iran. Is the account automatically restricted?

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 . …

451. How do financial sanctions relate to existing legal authorities in this context?

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. What are the requirements of CAATSA section 105 related to the imposition of sanctions on the IRGC, and how are those requirements being implemented?

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. The President has amended E.O. 13694 to cover “misappropriation of information.” What does that term mean? Does that mean that Treasury will impose sanctions related to the publication of information by American whistleblowers or members of the press?

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 under… Read more

534. Before October 13, 2017, wasn’t the IRGC already subject to sanctions? What’s different about applying terrorism-related sanctions to the IRGC and foreign persons that are officials, agents, or affiliates of the IRGC?

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. What is a SPECIAL PURPOSE ACCOUNT for purposes of the National Defense Authorization Act's (NDAA) significant reduction exception?

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 265 ).… Read more

549. In light of the recent earthquake in Iran, how can I help the Iranian people while making sure to abide by U.S. sanctions?

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 OFAC… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence