Frequently Asked Questions

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 … for payment or other agreed-to compensation. With respect to goods exported to or from Iran… Read more

1231. What entities or jurisdictions are excluded from transactions authorized under Venezuela General License (GL) 46?

… located in or organized under the laws of the Russia Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, and the Republic of Cuba—as well as any entity … located in or organized under the laws of the Russia Federation, the Islamic Republic of… Read more

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, … entry in addition to the tag for the other sanctions program(s) (e.g., the “[SDGT]” tag, the… Read more

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 … of the Iranian Transactions and Sanctions Regulations (ITSR) authorize the exportation to… Read more

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. … or other transactions and activities prior to the identification of the financial sector of… Read more

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. … appropriate steps to avoid, among other things, undue impacts on the access of the people of Iran… Read more

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 … to any sanctions program administered by OFAC, regardless of whether the Government of… Read more

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 … certain NGO activities in sanctioned jurisdictions such as the Crimea Region of Ukraine, … Read more

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 … is effective, the only laptops, tablets, and other computing devices that may be exported to Iran… Read more

1244. How will OFAC assess specific license applications to perform any contingent contracts that are executed pursuant to Venezuela General License (GL) 49?

… on transactions involving persons located in the Russian Federation, the Islamic Republic of Iran, the Democratic People's Republic of Korea, the Republic of Cuba, the People's Republic of … on transactions involving persons located in the Russian Federation, the… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence