Frequently Asked Questions

417. Are payments or the facilitation of payments not involving U.S. persons to Iranian civil aviation authorities for overflights of Iran or landing in Iran by aircraft that are owned by a non-U.S. person and registered outside the United States sanctionable under U.S. law?

… Persons List ( SDN List ), payments of charges for services rendered by the Government of Iran in connection with the overflight of Iran or landing in Iran of aircraft owned by a non-U.S. person and registered outside the United States are not …

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

303. Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under IFCA's section 1246(a)(1)?

… to or for Iranian persons on the SDN List to or for any person designated in connection with Iran’s support for international terrorism or WMD proliferation, or for activities with respect to Iran for which sanctions have been imposed (e.g., knowingly engaging in… Read more

300. For purposes of sanctions under section 1245, how will I know which sectors are controlled by Iran’s Islamic Revolutionary Guard Corps?

… with respect to which sectors of the Iranian economy are controlled directly or indirectly by Iran’s Islamic Revolutionary Guard Corps (IRGC). Given the opaque business environment in Iran and the significant role that the IRGC plays in the Iranian economy, OFAC… Read more

36. I understand blocking a transaction, but what is meant by rejecting a transaction? When should a transaction be rejected rather than blocked?

… transfer between two third-country companies (non-SDNs) involving an export to a company in Iran that is not otherwise subject to sanctions. Since there is no interest of the blocked person (e.g., the Government of Iran, and Iranian financial institution, or an… Read more

482. What key changes did the December 23, 2016 regulatory amendment to the Iranian Transactions and Sanctions Regulations (ITSR) make relating to the exportation and reexportation of agricultural commodities, medicine, and medical devices to Iran?

… amendment primarily expands the scope of medical devices that can be exported or reexported to Iran without specific authorization. It authorizes the exportation or reexportation to Iran of all items meeting the definition of the term “medical device” as defined… Read more

255. Do the section 504 modifications of the TRA restrict any other dealings with Iran?

… Company (“NICO”), or otherwise for the purchase of petroleum or petroleum products from Iran, are only eligible for the significant reduction exception if the FFIs adhere to the … in the country with primary jurisdiction over the FFI, and do not repatriate the funds to … Read more

348. May U.S. persons employ agents in Iran to facilitate sales, create or fund a physical sales presence on the ground in Iran, or utilize Iranian commercial marketing services in furtherance of exports authorized under 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?

… 348 … No. Section 560.540 of the ITSR does not authorize the employment of persons in Iran to facilitate sales, the maintenance of a physical sales presence in Iran, or the utilization of Iranian marketing services. However, the exportation of certain … to 31… Read more

188. If I am a non-U.S. company that exports information and communications technology to Iran or Syria, will I be designated under the GHRAVITY E.O.?

… are designed primarily to address the need to prevent entities located in whole or in part in Iran and Syria from facilitating or committing serious human rights abuses. These measures are … with each other and the outside world. That said, those providing communications… Read more

363. Is the exportation or reexportation by non-U.S. persons of agricultural commodities, medicine, or medical devices that are subject to the Export Administration Regulations (EAR) to Iran authorized?

… person may export or reexport agricultural commodities, medicine, or medical devices to Iran under the relevant general licenses in the ITSR , provided that the items are subject to … and medical devices general license to arrange for the exportation or reexportation to … Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence