Frequently Asked Questions

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

181. Will the U.S. refrain from sanctioning foreign financial institutions that receive funds from the Central Bank of Iran (CBI) to repay loans? What if these loans were granted for projects that might be subject to the food, medicine, and medical device exemptions under the National Defense Authorization Act (NDAA)?

… allow sanctions based on transactions for the sale of food, medicine, or medical devices to Iran. Payments related to the export of broader humanitarian items would be dealt with in our … from sanctioning foreign financial institutions that receive funds from the Central Bank of… Read more

341. May a non-U.S. person export, reexport, or provide to Iran hardware or software that is subject to Commerce's Export Administration Regulations (EAR) pursuant to 31 CFR § 560.540?

… export the smartphones from its third-country manufacturing facility directly or indirectly to Iran. See FAQs 1087–1089 and 1110 . Date Updated: May 16, 2024 … May a non-U.S. person export, reexport, or provide to Iran hardware or software that is subject to… Read more

154. How does the Treasury Department determine whether a transaction or financial service is “significant” for purposes of the Iranian Financial Sanctions Regulations (IFSR)?

… transaction(s) and a blocked Islamic Revolutionary Guard Corps individual or entity or blocked Iran-linked financial institution; (4) the impact of the transaction(s) on the goals of the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA… Read more

811. Can I ship agricultural commodities, food, medicine, and medical devices to Iran via IRISL or E-Sail on or after June 8, 2020?

… that allow for the sale of agricultural commodities, food, medicine, and medical devices to Iran by U.S. and non-U.S. persons (see, e.g., FAQ 637 ). However, these authorizations and … that knowingly engage in certain transactions with IRISL or E-Sail, even for the sale to… Read more

237. How does the effect of this determination compare to the effect of section 1(a) of Executive Order 13622 as to transactions with National Iranian Oil Company (NIOC)?

… these authorities is that the National Defense Authorization Act (NDAA) exception in the Iran Threat Reduction and Syria Human Rights Act (TRA) section 312 is limited to transactions or financial services for the purchase of petroleum or petroleum products from Iran… Read more

171. Does the NDAA (National Defense Authorization Act) repeal or amend Section 104(c) of CISADA (the Comprehensive Iran Sanctions, Accountability, and Divestment Act)?

… Defense Authorization Act) repeal or amend Section 104(c) of CISADA (the Comprehensive Iran Sanctions, Accountability, and Divestment Act)? …

347. Are there any restrictions as to the use of the Farsi language in authorized advertising or software?

… 347 … U.S. sanctions on Iran do not impose any restrictions as to the use of the Farsi language. See FAQ 337 . Date …

179. Does the definition of “significant financial transaction” exclude the passive holding of Central Bank of Iran (CBI) reserves? Is the U.S. willing to give assurances that this will not be a basis for sanctions?

… of “significant financial transaction” exclude the passive holding of Central Bank of Iran (CBI) reserves? Is the U.S. willing to give assurances that this will not be a basis for …

191. What does Executive Order 13608 “Prohibiting Certain Transactions with and Suspending Entry into the United States of Foreign Sanctions Evaders with Respect to Iran and Syria” do?

… to violate, conspired to violate, or caused a violation of U.S. sanctions on Syria or Iran. This E.O. also gives Treasury the authority to impose sanctions on foreign persons who have … with and Suspending Entry into the United States of Foreign Sanctions Evaders with Respect to… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence