Frequently Asked Questions

174. What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “owned or controlled by the government of a foreign country,” “food, medicine, and medical devices,” “foreign financial institution,” “Iranian financial institution,” “significantly reduced,” and “whether the price and supply of petroleum and petroleum products produced in countries other than Iran is sufficient”?

… Financial Sanctions Regulations (IFSR), which implement section 104(c) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), identify factors to be used in … the following: The holding of nostro, vostro, or loro accounts for or with the Central Bank of… Read more

150. Where can I find a list of Islamic Revolutionary Guard Corps (IRGC) affiliates and Iran-linked financial institutions “blocked pursuant to the International Emergency Economic Powers Act (IEEPA)”?

… The list of blocked IRGC affiliates and blocked Iran-linked financial institutions is dynamic and is based on the identity of “designated” … listings of designated IRGC entities will be followed by the tag [IRGC]; those of designated Iran-linked financial… Read more

164. The Iranian Transactions Regulations (ITR) authorize U.S. depository institutions and U.S. registered brokers or dealers in securities to process transfers of funds to or from Iran if the transfer is a non-commercial, personal remittance. Are U.S. depository institutions and U.S. registered brokers or dealers in securities still authorized to process such payments to or from a Government of Iran-owned bank that is not otherwise designated pursuant to another part of 31 C.F.R. Chapter V?

… brokers or dealers in securities to process noncommercial, personal remittances to or from Iran provided that the payment is not made by, to, or through a financial institution designated … are blocked solely pursuant to E.O. 13599. Exempt or authorized transactions to or from… Read more

844. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions, or other activities that would be authorized under the Iranian Transactions and Sanctions Regulations and General License (GL) L if engaged in by a U.S. person, involving Iranian financial institutions (Iranian FIs) sanctioned pursuant to E.O. 13902?

… for engaging in the sale of agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in E.O. 13902 and other … List of Specially Designated Nationals and Blocked Persons (SDN List) in connection with … Read more

259. What can a foreign financial institution (FFI) do with the funds resulting from the import of Iranian-origin goods or services once the funds are credited to an account? Can funds be transferred to other accounts?

… to fall within the bounds of the significant reduction exception , any funds owed to Iran as a result of the bilateral trade transaction must be credited to an "account located in … at the same FFI that facilitated the transaction for the importation of goods or services… Read more

932. Do U.S. sanctions prohibit U.S. persons from visiting, or making donations to, the Imam Reza Holy Shrine in Mashhad, Iran?

… URGENT NOTE: The U.S. Department of State cautions against any travel by U.S. persons to Iran. The Department of State has issued a Level Four Travel Advisory ( Do Not Travel ) for Iran due to the risk of kidnapping, arbitrary arrest, and detention of U.S.… Read more

1088. What are OFAC’s due diligence expectations for cloud-based service or software providers whose services and software support communication tools are authorized by 31 CFR § 560.540?

… or software provider whose non-Iranian customers provide services or software to persons in Iran via the cloud may rely upon the authorization in 31 CFR § 560.540 to provide access to Iran, provided that such provider conducts due diligence based on information… Read more

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

… 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 and Syria by their… Read more

178. Are barter trades involving the Central Bank of Iran (CBI) considered “financial transactions” under Section 1245?

… Are barter trades involving the Central Bank of Iran (CBI) considered “financial transactions” under Section 1245? … Are barter trades involving the Central Bank of Iran (CBI) considered “financial transactions” under Section 1245? …

597. What is the purpose of Executive Order (E.O) 13846 of August 6, 2018, “Reimposing Certain Sanctions With Respect to Iran”?

… of the Treasury on May 8, 2018 , E.O. 13846 reimposes specified sanctions relating to Iran following relevant wind-down periods, i.e., on or after August 7, 2018 or November 5, 2018, … Executive Order (E.O) 13846 of August 6, 2018, “Reimposing Certain Sanctions With Respect to… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence