Frequently Asked Questions

671. How are the terms “significant transaction or transactions; significant financial services; significant financial transaction” interpreted for purposes of correspondent or payable-through account sanctions set forth in section 2 of E.O. 13871?

… practices; (g) whether the transactions solely involve the passive holdings of Central Bank of Iran (CBI) reserves or repayment by the CBI of official development assistance or the transfer of funds required as a condition of Iran’s membership in an international… Read more

234. What is the effect of the National Iranian Oil Company (NIOC) determination? Are there CISADA implications?

… 234 … As a result of the Iran Threat Reduction and Syria Human Rights Act (TRA) section 312 determination, NIOC now is also a person described under section 104(c)(2)(E)(i) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA)… Read more

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.” … Are there any exceptions to the sanctions provisions in the National Defense …

117. Specific to Iran I hold a specific license to sell agricultural goods, medicine, or medical devices to Iran. The general license at section 560.532(a)(4) of the Iranian Transactions and Sanctions Regulations (ITSR) authorizes me to accept a letter of credit issued by an Iranian financial institution whose property and interests in property are blocked solely pursuant to the ITSR (i.e., an Iranian financial institution that is not listed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List)). The general license, however, also states that a U.S. financial institution may not advise, confirm, or otherwise deal in that credit. How am I supposed to know if/when a letter of credit has been issued for my sale and how do I get paid? My bank accounts are all at U.S. financial institutions.

… or -controlled foreign entity, an Iranian financial institution, or the Government of Iran, unless otherwise authorized by OFAC. In none of these circumstances, however, may there be … to Executive Order 13599 and the Iranian Transactions and Sanctions Regulations. … Specific to… Read more

177. If the Central Bank of Iran (CBI) is involved in providing settlement services for a transaction, or is otherwise acting solely as an intermediary in a transaction between a non-designated Iranian bank and a foreign financial institution, is the foreign financial institution deemed to be engaging in a transaction with the CBI?

… role would likely be viewed as a transaction “with” the CBI. … If the Central Bank of Iran (CBI) is involved in providing settlement services for a transaction, or is otherwise acting …

842. What does General License L (GL L) authorize with respect to the financial sector of Iran and Iranian financial institutions (Iranian FIs) now sanctioned pursuant to Executive Order (E.O.) 13902?

… (including any sale) of agricultural commodities, food, medicine, or medical devices to Iran; pursuant to Section 12 of E.O. 13902, the prohibitions of E.O. 13902 do not apply with … … What does General License L (GL L) authorize with respect to the financial sector of … Read more

215. What is the difference, in practical effect, between this and a designation under one of your other authorities, like E.O. 13382?

… 215 … The July 31, 2012 Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) finding prohibits the opening or …

265. Can the funds be used for sales made under the Humanitarian Exception?

… sale of agricultural commodities, food, medicine, or medical devices from third countries to Iran). Funds deposited in the RECIPIENT ACCOUNT or the SPECIAL PURPOSE ACCOUNT can be used to pay …

209. What happens to the correspondent and payable-through accounts held by Bank of Kunlun in the United States?

… 209 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . To our knowledge, Bank of …

169. What is the NDAA?

… to U.S. jurisdiction of all Iranian financial institutions, including the Central Bank of Iran (CBI). It also aims to reduce Iranian oil revenues and discourage transactions with the CBI …

Frequently Asked Questions

Office of Terrorism and Financial Intelligence