Frequently Asked Questions

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

… 932 … 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

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

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

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

243. How can I send personal remittances to or from Iran under the Iranian Transaction and Sanctions Regulations (ITSR)?

… ITSR authorize the transfer of funds that are noncommercial and personal in nature to or from Iran or for or on behalf of an individual ordinarily resident in Iran, other than an individual whose property and interests in property are blocked pursuant to § …… Read more

362. Is the exportation or reexportation of non-U.S.-origin agricultural commodities, medicine, or medical devices by a U.S. person to Iran authorized?

… the United States would be authorized to arrange for the exportation from a third country to Iran of agricultural commodities produced in the third country if those commodities would be … of non-U.S.-origin agricultural commodities, medicine, or medical devices by a U.S. person… Read more

366. Do I still need to come in to OFAC for a specific license to export certain types of agricultural commodities to Iran?

… licensing. As a result, persons seeking authorization for the exportation or reexportation to Iran of castor beans, castor bean seeds, certified pathogen-free eggs (unfertilized or … come in to OFAC for a specific license to export certain types of agricultural commodities to… Read more

826. What options exist for exporting humanitarian goods to Iran outside the Swiss Humanitarian Trade Arrangement (SHTA)?

… setting out existing exceptions to U.S. sanctions for the export of humanitarian goods to Iran. Foreign governments and foreign financial institutions interested in establishing a … in the October 25, 2019 guidance. … What options exist for exporting humanitarian goods to… Read more

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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence