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 …

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

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

… 610 … 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 … and after-market parts manufacturing relating to such vehicles. … What is… 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

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

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

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

163. What are the differences and similarities between E.O. 13599 and the Iranian Transactions Regulations (ITR)?

… 163 … The ITR prohibit prohibit virtually all direct or indirect transactions involving Iran or the Government of Iran by U.S. persons or with a nexus to the United States, unless otherwise authorized by OFAC or … requires U.S. persons to block all property and… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence