Frequently Asked Questions

182. Is there a difference between entities that have been designated by the United States Government for illicit conduct, such as proliferation of weapons of mass destruction or support for terrorism, and those that are being blocked under E.O. 13599? How can I tell which entities appear on the Specially Designated National (SDN) List for which reasons?

182 … Both blocked and designated entities appear on the SDN List . “Blocked” persons, in the context of E.O. 13599 , appear on the SDN List due to the United States Government’s identification of these entities as the Government of Iran and/or as an Iranian financial institution . Such entities… Read more

339. With respect to the authorization in 31 CFR § 560.540(a)(3), do exporters need to make a determination as to whether an export of an item or service included in the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications is “incident to communications”?

339 … No. The 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications lists software, hardware, and related services determined to be “incident to communications” for purposes of the authorization in 31 CFR § 560.540(a)(3) of the ITSR. Date Updated: May 16, 2024 … With… Read more

183. Why did the President issue the GHRAVITY E.O.?

183 … The GHRAVITY E.O. follows prior Executive orders issued by the President in response to the commission of human rights abuses by the Governments of Iran and Syria. With the GHRAVITY E.O., the President recognized that the commission of serious human rights abuses against the people of Iran… Read more

184. What does the GHRAVITY E.O. do?

184 … The GHRAVITY E.O. blocks (i.e., freezes) the property and interests in property of, among others, any person determined by the Secretary of the Treasury, in consultation with or at the recommendation of the Secretary of State, (1) to have operated, or to have directed the operation of,… Read more

185. What type of activities does the GHRAVITY E.O. target?

185 … The GHRAVITY E.O. targets the provision and use of information and communications technology to facilitate computer or network disruption, monitoring, or tracking that could assist in or enable serious human rights abuses by or on behalf of the Government of Iran or the Government of Syria.… Read more

186. How do I know that a person has been designated under the GHRAVITY E.O.?

186 … 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

187. Does the GHRAVITY E.O. prohibit me from exporting technology to companies that do business with Iran or Syria?

187 … 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… Read more

188. If I am a non-U.S. company that exports information and communications technology to Iran or Syria, will I be designated under the GHRAVITY E.O.?

188 … 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… Read more

189. Would I need authorization from OFAC or BIS if I wanted to export goods or technology to persons blocked under the GHRAVITY E.O.?

189 … Yes. For more information regarding exports of goods or technology to persons blocked under the GHRAVITY E.O. please contact OFAC or BIS. … Would I need authorization from OFAC or BIS if I wanted to export goods or technology to persons blocked under the GHRAVITY …

340. What should I do if I am unsure whether an item or service is covered by 31 CFR § 560.540?

340 … 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, 2024 … What should… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence