Frequently Asked Questions

The term “knowingly” as used in the IFSR means that a person has actual knowledge or should have known of specific conduct, a circumstance, or a result. In other words, the IFSR could be implicated if the Treasury Department finds that a foreign financial institution knew or should have known that… Read more

As set out in the IFSR , in determining whether a transaction or financial service is “ significant ,” the Treasury Department may consider: (1) the size, number, frequency, and nature of the transaction(s); (2) the level of awareness of management of the transaction(s) and whether or not the… Read more

A finding by the Treasury Department that a foreign financial institution knowingly engages in one or more of the sanctionable activities is necessary before the Treasury Department can prohibit or impose strict conditions on the opening or maintaining in the United States of correspondent accounts… Read more

Any U.S. person who violates the correspondent account provisions of the IFSR may be subject to civil penalties of up to the greater of $250,000 or twice the transaction value, and criminal penalties for willful violations of up to $1 million and 20 years in prison. A U.S. financial institution may… Read more

The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) provides for a waiver of the sanctions under the Iranian Financial Sanctions Regulations ( IFSR )  if the Secretary of the Treasury determines that a waiver is necessary to the national interest of the United …

The text of the Iranian Financial Sanctions Regulations (IFSR) can be found here .  …

E.O. 13599 requires U.S. persons to block (i.e., freeze) all property and interests in property of the Government of Iran, including the Central Bank of Iran, and of all Iranian financial institutions, which also includes the Central Bank of Iran. This means that all individuals and entities that… Read more

Generally yes. Under new General License A, almost all transactions that are authorized under existing general licenses issued pursuant to the Iranian Transactions Regulations (ITR) or under existing OFAC specific licenses will continue to be authorized under the authority of E.O. 13599. However,… Read more

Yes. E.O. 13599 builds upon the prohibitions of the ITR, and the prohibitions of the ITR remain in effect. …

Yes. These goods have otherwise come in contact with Iran and thus do not fall within the carve-out to the definition of Iranian-origin goods or goods of Iranian-origin at section 560.306 (b)(2) of the ITSR . However, if these goods are being exported or reexported to Iran under an authorization… Read more