Frequently Asked Questions

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

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

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

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

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

1247. Do non-U.S. persons face sanctions risk for engaging in transactions authorized by General Licenses (GL) 46B, 51A, and 52?

… located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People's Republic of Korea, the Republic of Cuba, or any entity that is … Venezuelan-origin minerals, including gold, in the Russian Federation, the Islamic… 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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence