Frequently Asked Questions

636. Can I receive payment for activities undertaken during the wind-down period if the payment involves a person that has been added to the SDN List, including a person that was previously on the List of Persons Blocked Solely Pursuant to E.O. 13599 (the “E.O. 13599 List”) but is now designated under another authority?

… a non-designated Iranian financial institution – or a person designated in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction, …

633. Under what circumstances are goods or services considered “fully provided or delivered” prior to the expiration of the relevant wind-down period, as referenced in FAQ 631 above?

… for payment or other agreed-to compensation. With respect to goods exported to or from Iran, at a minimum, title to the goods must have transferred to the relevant party … Under what …

440. 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) authorize the exportation to Iran of fee-based desktop publishing software and productivity software suites used to publish documents, presentations, spreadsheets, charts, music, movies, and digital images?

… of the Iranian Transactions and Sanctions Regulations (ITSR) authorize the exportation to Iran of fee-based desktop publishing software and productivity software suites used to publish …

346. What kind of due diligence is required for the exportation of fee-based services, software, or hardware authorized by 31 CFR § 560.540?

… to any sanctions program administered by OFAC, regardless of whether the Government of Iran or other end-user appears on OFAC’s Specially Designated Nationals and Blocked Persons List …

1108. Does OFAC’s issuance of general licenses (GLs) as outlined in FAQ 1105 restrict the scope of any existing exemptions or OFAC authorizations for humanitarian activities?

… certain NGO activities in sanctioned jurisdictions such as the Crimea Region of Ukraine, Iran, and Syria, which have not been amended by this action, and pre-existing web general …

442. For purposes of category (5) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications, what would be considered “software required for effective consumer use” of personal computing devices, laptops, and tablets?

… is effective, the only laptops, tablets, and other computing devices that may be exported to Iran are ones with an APP of 1 WT or less. Date Updated: May 16, 2024 … For purposes of category …

624. What are the implications of subsection 1(a)(iii) of E.O. 13846?

… appropriate steps to avoid, among other things, undue impacts on the access of the people of Iran to humanitarian items, telecommunications, and other basic services. … What are the …

843. I’m a U.S. person that relied on general or specific licenses issued pursuant to the Iranian Transactions and Sanctions Regulations (ITSR) to conduct humanitarian-related or other transactions and activities prior to the identification of the financial sector of Iran and sanctioning of a number of Iranian financial institutions (Iranian FIs) under E.O. 13902. Is any further authorization needed to conduct such transactions following these actions?

… or other transactions and activities prior to the identification of the financial sector of Iran and sanctioning of a number of Iranian financial institutions (Iranian FIs) under E.O. …

314. Can an exporter of agricultural commodities, food, medicine, or medical devices get paid out of a Central Bank of Iran (CBI) account at a foreign financial institution (FFI) in a country with a significant reduction exception, even though the exporter is located in a third-country? Can the third-country exporter’s bank handle this transaction?

… agricultural commodities, food, medicine, or medical devices get paid out of a Central Bank of Iran (CBI) account at a foreign financial institution (FFI) in a country with a significant …

616. Can countries that receive a significant reduction exception under NDAA 2012 purchase oil through NIOC and NICO without facing sanctions?

… for transactions with NIOC and NICO for the purchase of petroleum or petroleum products from Iran while the exception applies. In addition, IFCA provides for sanctions on persons that …

Frequently Asked Questions

Office of Terrorism and Financial Intelligence