Frequently Asked Questions

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

262 … In order for the National Defense Authorization Act's ( NDAA ) significant reduction exception to apply on or after February 6, 2013, funds withdrawn from the RECIPIENT ACCOUNT or SPECIAL PURPOSE ACCOUNT at the FFI may only be used to pay for bilateral trade or purchases relating to the… Read more

599 … E.O. 13846 is effective at 12:01 a.m. eastern daylight time (EDT) on August 7, 2018. However, certain sanctions set out in E.O. 13846 apply only to activities that take place on or after November 5, 2018, as set out in FAQ 598 above and in the relevant provisions of E.O. 13846. E.O. 13846 is… Read more

600 … Subsection 1(a)(iv) authorizes blocking sanctions pursuant to section 1244(c)(1)(A) of IFCA on persons determined to: (A) be part of the energy, shipping, shipbuilding sectors of Iran; (B) operate a port in Iran; or (C) knowingly provide significant support to certain other persons sanctioned… Read more

601 … Yes. E.O. 13846 broadens the scope of the sanctions that were in effect prior to January 16, 2016 and provides for greater consistency in the administration of Iran-related sanctions provisions. See FAQ 597 . These added measures are as follows: i. Subsection 1(a)(iii)(B): Providing new… Read more

602 … To provide clarity and consolidate relevant authorities into a single document, E.O. 13846 revokes E.O.s 13716 and 13628, and continues in effect relevant provisions from those two revoked E.O.s. See FAQ 597  and FAQ 598 . Provisions of E.O. 13846 that carry forward relevant provisions of E.O… Read more

603 … Yes. OFAC is taking action under section 7 of E.O. 13846 to continue in effect the designations of persons who were designated pursuant to E.O. 13628 at the time of the issuance of E.O. 13846. See FAQ 602 . U.S. persons must continue to block the property and interests in property of these… Read more

604 … The Treasury Department implementation authorities set out in section 1 of E.O. 13574 for “menu-based” sanctions under ISA have been superseded by the implementation authorities for “menu-based” sanctions under a broader range of authorities that include ISA , CISADA , TRA , and IFCA , and… Read more

605 … E.O. 13846 implements provisions of, and provides additional tools related to, ISA , CISADA , TRA , and IFCA that were contained in the prior E.O.s. These include: i. Invoking the President’s authority under the International Emergency Economic Powers Act (IEEPA) to supplement statutory… Read more