Frequently Asked Questions

533. What are the requirements of CAATSA section 105 related to the imposition of sanctions on the IRGC, and how are those requirements being implemented?

… Act” (Public Law 115-44) ( CAATSA ), which, among other things, imposes new sanctions on Iran. Section 105 of CAATSA requires the imposition of sanctions applicable pursuant to the global terrorism Executive Order 13224 on Iran’s Islamic Revolutionary Guard Corps… Read more

604. Why do the sanctions set out in E.O.s 13574 and 13590 not appear in E.O. 13846?

… set out in section 1 of E.O. 13590 — relating to development of petroleum resources in Iran and Iran’s domestic production of petrochemical products — were incorporated into subsections … set out in section 1 of E.O. 13590 — relating to development of petroleum… Read more

639. Why are some persons that had been blocked solely pursuant to E.O. 13599 now designated pursuant to other authorities, such as E.O. 13224 and E.O. 13382?

… proliferation), and E.O. 13553 (relating to serious human rights abuses by the Government of Iran) on October 16, 2018, and November 5, 2018. These included persons that had been removed … on November 5, 2018 as persons identified as meeting the definitions of the “Government of… Read more

630. Is the provision or delivery of goods or services to an Iranian counterparty after November 4, 2018 allowed?

… that allow for the sale of agricultural commodities, food, medicine, and medical devices to Iran by U.S. persons and non-U.S. persons. However, these authorizations and exceptions do not … Nationals and Blocked Persons (SDN List) that have been designated in connection with… Read more

233. Isn’t the National Iranian Oil Company (NIOC) already subject to sanctions?

… products to NIOC that fall below the dollar threshold that could trigger sanctions under the Iran Sanctions Act ). Executive Order 13622 also provides authority for the Secretary of the … Executive Order 13622. In addition, NIOC was already blocked as an entity of the Government… Read more

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 … of “significant financial transaction” exclude the passive holding of Central Bank of Iran… Read more

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

158. Can the application of any part(s) of the Iranian Financial Sanctions Regulations (IFSR) be waived by the Department of the Treasury?

… The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) provides for a waiver of the … The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) provides for a waiver of the …

173. Are there any exceptions to the sanctions provisions in the National Defense Authorization Act for Fiscal Year 2012 (as amended) (NDAA for FY 2012)?

… conducting or facilitating a transaction for the sale of food, medicine, or medical devices to Iran.” … conducting or facilitating a transaction for the sale of food, medicine, or medical devices to Iran.” …

212. Does this finding affect Bank of Kunlun's branches or subsidiaries around the world? Does this finding affect any holding companies?

… Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . The prohibitions … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence