Frequently Asked Questions

825. How can parties participate in the Swiss Humanitarian Trade Arrangement (SHTA) to export humanitarian goods to Iran?

… are authorized pursuant to sections 560.530, 560.532, and 560.533 of the ITSR. In addition, General License 8A provides additional authorizations that may be necessary for such … Oil Company under Executive Order (E.O.) 13224, as amended. For further information regarding… Read more

990. May a debit to an account of a person blocked pursuant to Executive Order (E.O.) 14024 be authorized as a transaction that is ordinarily incident and necessary to a licensed transaction?

… An authorization for transactions that are ordinarily incident and necessary to a transaction licensed pursuant to E.O. 14024 does not implicitly authorize a debit to a blocked account on the … authorized as transactions ordinarily incident and necessary to a licensed… Read more

1198. In light of the designation of Shreya Life Sciences Private Limited (Shreya), are U.S. persons authorized to engage in transactions related to pharmaceutical and other humanitarian-related goods involving Shreya and its subsidiaries?

… Yes. As a general matter, humanitarian trade is not the target of U.S. sanctions. OFAC has issued Russia-related General License (GL) 6D , which authorizes, among other things, certain transactions related to … engage in authorized transactions involving Shreya… Read more

579. Will foreign persons be subject to sanctions under CAATSA for engaging in activity with RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest?

… 5 of UFSA , as amended by section 226 of CAATSA, if U.S. persons would not require specific licenses from OFAC to participate in such a transaction. Therefore, activity authorized by General License 14, and occurring within the time period authorized by … Read more

509. Is there a wind-down or safe harbor provision for the prohibitions in Executive Order (E.O.) 13808?

… General License 1, which expired on September 25, 2017, provided a wind-down period with respect to contracts and other agreements that were in effect prior to August 25, 2017. That general license provided 30 days in which to conduct all transactions and… Read more

571. I am a U.S. person holding accounts for or other property of an entity or individual that was designated under E.O. 13661 or E.O. 13662, or blocked pursuant to OFAC’s 50 Percent Rule on April 6, 2018 as a result of such a designation. Does General License (GL) 13R allow me to unblock this property?

… pursuant to OFAC’s 50 Percent Rule on April 6, 2018 as a result of such a designation. Does General License (GL) 13R allow me to unblock this property? … pursuant to OFAC’s 50 Percent Rule on April 6, 2018 as a result of such a designation. Does General License… Read more

1141. Does Venezuela General License (GL) 45B authorize U.S. persons to provide certain services, including refueling services, repair, and maintenance, to blocked Conviasa aircraft that are carrying out flights for the exclusive purpose of repatriating Venezuelan nationals from a third country in the Western Hemisphere to Venezuela?

… Does Venezuela General License (GL) 45B authorize U.S. persons to provide certain services, including refueling … Does Venezuela General License (GL) 45B authorize U.S. persons to provide certain services, including refueling …

837. What did the September 24, 2020 amendment to the Cuban Assets Control Regulations (CACR) do?

… please see FAQ 731 . Professional research and professional meetings in Cuba. Eliminates the general authorization in § 515.564(a)(2) related to attendance at, or organization of, … or conferences in Cuba. Persons subject to U.S. jurisdiction are no longer authorized via this… Read more

1089. Can persons seeking to export software, services, or hardware to Iran in support of internet freedom apply for a specific license from OFAC if the export is not authorized by 31 CFR § 560.540?

… in support of internet freedom in Iran that are not exempt transactions or authorized by the general license in 31 CFR § 560.540 or other authorizations are encouraged to submit a specific license … software, services, or hardware to Iran in support of internet… Read more

823. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions or activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) that U.S. persons would be authorized to engage in under General License No. 8A (GL 8A)?

… No. Non-U.S. persons generally do not risk exposure under U.S. secondary sanctions relating to Iran for engaging in … agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in otherwise… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence