Frequently Asked Questions

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

637. Is it sanctionable for non-U.S., non-Iranian persons to engage in transactions related to the provision of humanitarian and consumer goods to Iran?

… that allow for the sale of agricultural commodities, food, medicine, and medical devices to Iran from the United States or by U.S. persons or U.S.-owned or -controlled foreign entities. … allowances for sales of food, agricultural commodities, medicine, and medical devices to… Read more

301. How will the determination be made as to whether materials are used in a manner that would make them subject to sanctions under section 1245 of IFCA?

… facilitating a significant financial transaction for the sale, supply, or transfer to or from Iran of the materials listed in 1245(d) – as described in part in Q&A 298 – will need to … involve the materials being sold, supplied, or transferred, directly or indirectly, to or… Read more

666. What does E.O. 13871 do?

… 13871 authorizes sanctions with respect to the iron, steel, aluminum, and copper sectors of Iran. Section 1 of E.O. 13871 authorizes blocking sanctions on any person determined by the … the Secretary of State: (i) to be operating in the iron, steel, aluminum, or copper sector of… Read more

149. What activities by foreign financial institutions can subject them to CISADA sanctions?

… of a foreign financial institution are: Facilitating the efforts of the Government of Iran (GOI) to acquire or develop Weapons of Mass Destruction (WMD) or delivery systems for WMD or … , or 1929 , or any other Security Council resolution that imposes sanctions with respect to… Read more

828. I want to help with the humanitarian response to public health concerns, including the Coronavirus Disease 2019 (COVID-19) outbreak, in Iran. What can I do to help while remaining compliant with U.S. sanctions?

… goods or assistance to the Iranian people in response to public health concerns in Iran, including the COVID-19 outbreak. The making of humanitarian donations to recipients in Iran from the United States or by U.S. persons, including the donation of medicine… Read more

54. I have an account with a W-8 showing an address in Iran. Is the account automatically restricted?

… In the absence of information proving to your satisfaction that the account holder is not in Iran, you should consider the account restricted based on the W-8 filing. See FAQ 37 . … I have an account with a W-8 showing an address in Iran. Is the account… Read more

610. What is considered Iran’s automotive sector for purposes of E.O. 13846?

… E.O. 13846 defines the automotive sector of Iran as the manufacturing or assembling in Iran of light and heavy vehicles including passenger cars, trucks, buses, minibuses, pick-up … What is considered Iran’s automotive sector for purposes of E.O… Read more

313. What is the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA)?

… Authorization Act for Fiscal Year 2013, and provides for several new sanctions related to Iran. IFCA authorizes broad sanctions on: certain activities related to Iran’s energy, shipping, and shipbuilding sectors; the sale, supply, or transfer to or from … Read more

292. What are the implications of IFCA on the provision of humanitarian goods to the people of Iran?

… transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran, as set out in more detail in Q&As 297 and 304 . … What are the implications of IFCA on the provision of humanitarian goods to the people of Iran? … transactions… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence