Frequently Asked Questions

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

831. How will OFAC define the sectors of the Iranian economy specified in Executive Order (E.O.) 13902 of January 10, 2020?

… of the Iranian economy means the production, procurement, devising, framing, or arranging in Iran of parts or materials to fabricate, shape, or form buildings or structures, including the … assembly, or construction of residential, commercial, or institutional buildings in… 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 … or for an Iranian person on the SDN List, to or for any person designated in connection… Read more

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 …… 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

297. Are there any exceptions to the sanctions provisions of section 1244 of IFCA?

… Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran or for the provision of humanitarian assistance to the people of Iran. b. The export of petroleum or petroleum products from Iran to a country with… 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

245. What does the Statement of Licensing Procedure on Support of Human Rights-, Humanitarian-, and Democracy-Related Activities with Respect to Iran do?

… of Licensing Procedure reflects procedures established pursuant to section 413 of the Iran Threat Reduction and Syria Human Rights Act (the TRA). These procedures stipulate that, as … in certain human rights-, humanitarian-, and democracy-related activities with respect 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)?

… 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 … May U.S.… Read more

847. As a result of the sanctions on the Iranian financial sector and certain Iranian financial institutions (Iranian FIs) pursuant to Executive Order (E.O.) 13902, do non-U.S. persons risk exposure to sanctions for continuing to engage in previously non-sanctionable trade involving the Iranian financial sector or E.O. 13902-sanctioned Iranian FIs, even after the end of the 45-day wind-down period?

… (including any sale) of agricultural commodities, food, medicine, or medical devices to Iran; or (ii) to transactions for the conduct of the official business of the United Nations … or otherwise excepted from sanctions: The sale, supply, or transfer of goods and services to… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence