Frequently Asked Questions

485. What key changes did the December 23, 2016 regulatory amendment to the Iranian Trade and Sanctions Regulations (ITSR) make to the definition of “Iranian-origin goods” or “goods of Iranian origin”?

… provided that such goods were not grown, produced, manufactured, extracted, or processed in Iran: (i) goods exported or reexported to Iran under an authorization issued pursuant to the ITSR (e.g., a medical device or a personal communications device exported or… Read more

642. Is the provision of certain associated services relating to the purchase of petroleum or petroleum products from Iran by persons in a country that has been granted a SRE sanctionable?

… 642 … Many U.S. sanctions related to Iran include an exception for countries that have received a SRE under section 1245(d)(4)(D) of … sanctionable transactions). To the extent the purchase of petroleum or petroleum products from Iran and the processing of the… Read more

830. Will OFAC target Iranian manufacturers of medicines, medical devices, or products used for sanitation or hygiene or as personal protective equipment for use in Iran pursuant to Executive Order (E.O.) 13902 for continuing to manufacture these items? Will OFAC target persons conducting or facilitating transactions for the provision of such items to Iran if the transaction involves a person sanctioned under E.O. 13902?

… 830 … No. For the purposes of evaluating sanctions pursuant to E.O. 13902 , persons in Iran manufacturing medicines, medical devices, or products used for sanitation, hygiene, medical … items, personal protective equipment, and manufacturing safety systems, solely for use in… Read more

691. Will the provision of bunkering services to a non-Iranian vessel carrying sanctionable goods to or from Iran be subject to sanctions?

… 691 … If a non-Iranian vessel is transporting sanctionable goods to or from Iran (including, but not limited to, petroleum, petroleum products, or petrochemical products from Iran; goods used in connection with the automotive sector of Iran; or… Read more

1135. How can companies participate in the humanitarian channel in Qatar to export humanitarian goods to Iran?

… Hotline with specific questions. OFAC’s requirements related to humanitarian trade with Iran have not changed. Companies interested in participating in transactions pursuant to existing exceptions and authorizations for the conduct of humanitarian trade with Iran… Read more

692. Will the provision of bunkering services for an Iranian vessel be subject to sanctions?

… 1244(d)(1) of IFCA makes sanctionable knowingly selling, supplying, or transferring to or from Iran significant goods or services used in connection with Iran’s energy, shipping, or shipbuilding sectors. (See FAQ 289 above for an interpretation of …

160. Section 1 of E.O. 13599 blocks all property and interests in property of the Government of Iran, including the Central Bank of Iran, and of all Iranian financial institutions, that are in the United States, that come within the United States, or that come within the possession or control of U.S. persons (including overseas branches). Can you provide further clarification about this provision of E.O. 13599?

… persons to block (i.e., freeze) all property and interests in property of the Government of Iran, including the Central Bank of Iran, and of all Iranian financial institutions, which also includes the Central Bank of Iran. …

343. Does 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) authorize the exportation to Iran and importation into the United States or a third country of communication devices by persons travelling to and from Iran?

… … Yes. Section 560.540 of the ITSR authorizes the exportation, reexportation, or provision to Iran and the importation into the United States by an individual entering the United States directly or indirectly from Iran, of hardware and software authorized by… Read more

1119. Does General License (GL) O authorize all wind-down transactions for any vessel that was blocked on March 2, 2023? What if the vessel contains Iranian-origin merchandise?

… 1119 … Iran GL O authorizes U.S. persons to wind down all transactions otherwise prohibited by section 5 … Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR) , from engaging in most Iran-related transactions. Accordingly, for blocked vessels… Read more

242. The ITSR includes revisions to the ITR pertaining to the transfer of funds to or from Iran. Accordingly, how may I transfer funds to or from Iran that arise from, and are ordinarily incident and necessary to give effect to, an underlying transaction that is authorized under the ITSR?

… authorize United States depository institutions to process transfers of funds to or from Iran, or for the direct or indirect benefit of persons in Iran or the Government of Iran , if the transfer arises from, and is ordinarily incident and… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence