Frequently Asked Questions

342. Does 31 CFR § 560.540 continue to authorize U.S. persons located outside the United States to export or reexport to Iran certain specified hardware or software that is not subject to Commerce's Export Administration Regulations (EAR)?

… 560.540 of the ITSR continues to authorize the exportation, reexportation, or provision to Iran by U.S. persons located outside of the United States of certain specified hardware and … overseas branch of a U.S. company or a U.S.-owned or -controlled foreign entity may export to… Read more

805. Are non-U.S. persons exposed to sanctions for providing goods or services to, or engaging in other transactions with, a non-Iranian person sanctioned under section 3 of E.O. 13846?

… transaction for a person on the SDN List that has been designated in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction, … Guard Corps (IRGC), or other activity for which sanctions have been imposed with respect to … Read more

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

816. Is there a wind-down period for Executive Order 13902, “Imposing Sanctions with Respect to Additional Sectors of Iran” (E.O. 13902)?

… period for Executive Order 13902, “Imposing Sanctions with Respect to Additional Sectors of Iran” (E.O. 13902)? …

214. What is the licensing process for U.S. financial institutions that need to conduct transactions in order to close correspondent or payable-through accounts with a foreign financial institution sanctioned pursuant to the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA)?

… 214 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . Treasury regulations … accounts with a foreign financial institution sanctioned pursuant to the Comprehensive Iran… Read more

619. Are barter arrangements or other non-cash trade transactions involving petroleum, petroleum products, or petrochemical products originating from Iran sanctionable under the terms of E.O. 13846?

… the purchase or acquisition of petroleum, petroleum products, or petrochemical products from Iran. In addition, barter transactions knowingly conducted with NIOC, NICO, or the CBI also could … involving petroleum, petroleum products, or petrochemical products originating from… Read more

853. Can U.S. academic institutions provide online learning services to Iranian students located outside the United States? Can U.S. technology companies provide software and services to assist Iranian students in accessing online coursework?

… academic institutions, including their contractors, to export services to students located in Iran, or located outside of Iran but who are ordinarily resident in Iran (“Iranian students”), to sign up for and participate in certain undergraduate… Read more

211. If a foreign financial institution continues to do business with Bank of Kunlun, could that lead to a CISADA finding against the other institution?

… 211 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . Any foreign financial … behalf of designated Iranian banks – whether directly or indirectly – may face Comprehensive Iran… Read more

304. Are there exceptions to insuring, reinsuring, or underwriting sanctioned activities?

… Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran or for the provision of humanitarian assistance to the people of Iran can be insured, reinsured, or underwritten. b. A person that provides insurance, …

601. Does E.O. 13846 expand the scope of sanctions that were in effect prior to January 16, 2016 (Implementation Day of the JCPOA)?

… 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. … to subsection 1(a)(ii)); or c. Being part of the energy, shipping, or shipbuilding sectors of… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence