Frequently Asked Questions

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 … for transactions with NIOC and NICO for the purchase of petroleum or petroleum products from… Read more

623. Is there a wind-down or safe harbor provision for Section 8 of E.O. 13846?

… and necessary to the wind down of activities that had been authorized under the now-revoked Iran General License H. To the extent a U.S.-owned or -controlled foreign entity or a U.S. person … and necessary to the wind down of activities that had been authorized under the now-… Read more

437. Are mobile phone accessories and computer accessories and peripherals authorized for export under 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?

… conjunction with hardware specified in category (5) of the same are authorized for export to Iran under 31 CFR § 560.540. Authorized accessories for mobile phones include headsets, cases, … conjunction with hardware specified in category (5) of the same are authorized for export… Read more

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 … agricultural commodities, food, medicine, or medical devices get paid out of a Central Bank… Read more

832. What are significant goods or services used in connection with a sector of the Iranian economy specified in Executive Order (E.O.) 13902?

… knowingly engaged in a significant transaction for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with the construction, mining, … facilitated any significant financial transaction for the sale, supply, or transfer to or from… Read more

822. I'm a U.S. person that relied on general or specific licenses pursuant to 560.530, 560.532, or 560.533 of the ITSR to conduct humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) prior to their designations under E.O. 13224, as amended. Is any further authorization needed to conduct such transactions following the designations of the CBI and NIOC under E.O. 13224?

… ITSR to conduct humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) prior to their designations under E.O. … ITSR to conduct humanitarian-related transactions and activities involving the Central… Read more

398. Does OFAC consider entities over which one or more blocked persons exercise control, but of which they do not own 50 percent or more in the aggregate, to be blocked pursuant to OFAC’s 50 Percent Rule?

… Please also note that some sanctions programs (e.g., the Crimea region of Ukraine, Cuba, Iran, North Korea, Syria, and Venezuela) block certain persons without an OFAC designation; these … Please also note that some sanctions programs (e.g., the Crimea region of Ukraine, Cuba… Read more

845. Will there be a wind-down period for non-U.S. persons engaged in previously non-sanctionable activity involving the Iranian financial sector or Iranian financial institutions (FIs) that are now sanctioned pursuant to E.O. 13902?

… (including any sale) of agricultural commodities, food, medicine, and medical devices to Iran, with Iranian FIs sanctioned pursuant to E.O. 13902. In addition, GL L authorizes under … (including any sale) of agricultural commodities, food, medicine, and medical devices to… Read more

621. What is the prohibition on U.S.-owned or -controlled foreign entities, and how does it work?

… by certain Executive orders prohibiting trade and other dealings with, and investment in, Iran and blocking the GOI and Iranian financial institutions, or any regulation issued pursuant … by certain Executive orders prohibiting trade and other dealings with, and investment in,… Read more

951. Is Afghanistan subject to comprehensive sanctions?

… to sanctions programs administered and enforced by OFAC with regard to North Korea, Cuba, Iran, Syria, and the Crimea and so-called Donetsk People’s Republic and Luhansk People’s Republic … to sanctions programs administered and enforced by OFAC with regard to North Korea, Cuba… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence