Frequently Asked Questions

598. What does E.O. 13846 do?

598 … E.O. 13846 reimposes relevant blocking sanctions, correspondent and payable-through account sanctions, and menu-based sanctions previously provided for in E.O.s 13574, 13590, 13622, and 13645, which were revoked by E.O. 13716, and continues in effect sanctions authorities provided for in E.O.… Read more

690. What are the definitions of “copper” and “copper products”?

690 … The terms copper and copper products mean any raw, semi-fabricated, fabricated, or finished form of copper or copper alloy of all grades, sizes, and thicknesses, including in the following forms: ores and concentrates; copper mattes; cement copper (precipitated copper); refined, unrefined,… Read more

804. Do sanctions on COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. apply to its corporate parent and affiliates?

804 … COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. was determined by the Secretary of State on September 25, 2019, to meet the criteria for the imposition of sanctions under Executive Order (E.O.) 13846 , and the Secretary of State imposed certain sanctions, including blocking,… Read more

805. Are non-U.S. persons exposed to sanctions for providing goods or services to, or engaging in other transactions with, a non-Iranian person sanctioned under section 3 of E.O. 13846?

805 … No, non-U.S. persons are generally not exposed to sanctions for providing goods or services to, or engaging in other transactions with, a non-Iranian person sanctioned under section 3 of E.O. 13846 . However, please note that non-U.S. persons should ensure that the provision of goods or… Read more

810. On December 11, 2019, the State Department announced that it would designate the Islamic Republic of Iran Shipping Lines (IRISL) and E-Sail Shipping Limited (“E-Sail”) under Executive Order (E.O.) 13382, effective June 8, 2020. IRISL and E-Sail are already listed on the SDN List. What will be the impact of the State Department’s designation of these entities under E.O. 13382?

810 … On November 5, 2018, OFAC identified IRISL and E-Sail on the SDN List with the [IRAN] tag to indicate that they are entities meeting the definition of the Government of Iran whose property and interests in property are blocked pursuant to E.O. 13599. Following their designation by the State… Read more

1083. What actions were taken on September 15, 2022 related to certain quantum computing services?

1083 … On September 15, 2022, the Director of OFAC, in consultation with the Department of State, issued a determination pursuant to Executive Order (E.O.) 14071 , “Prohibitions Related to Certain Quantum Computing Services,” prohibiting the exportation, reexportation, sale, or supply, directly or… Read more

1084. For the purposes of the determination of September 15, 2022 made pursuant to Executive Order (E.O.) 14071, “Prohibitions Related to Certain Quantum Computing Services” (“the determination”), what is meant by the term “quantum computing services”?

1084 … For the purposes of the determination , OFAC anticipates publishing regulations defining this term to include any of the following services when related to quantum computing, quantum computers, electronic assemblies thereof, or cryogenic refrigeration systems related to quantum computing: … Read more

1086. For the purposes of the determination of September 15, 2022 made pursuant to Executive Order (E.O.) 14024, what is meant by the term “quantum computing sector of the Russian Federation economy”?

1086 … For the purposes of the determination of September 15, 2022 made pursuant to E.O. 14024 , OFAC interprets the term “quantum computing sector of the Russian Federation economy” to include activities related to products and services in or involving the Russian Federation in research,… Read more

1087. Does the general license at 31 CFR § 560.540 authorize the exportation of fee-based or no-cost cloud-based services and software to Iran that are used to support communications tools authorized by 31 CFR § 560.540?

1087 … Yes. Section 560.540(a)(1) of the ITSR authorizes the exportation to Iran of fee-based or no-cost cloud-based services incident to the exchange of communications over the internet. In addition, 31 CFR § 560.540(a)(2) authorizes the exportation to Iran of cloud-based software that is… Read more

1088. What are OFAC’s due diligence expectations for cloud-based service or software providers whose services and software support communication tools are authorized by 31 CFR § 560.540?

1088 … A cloud-based service or software provider whose non-Iranian customers provide services or software to persons in Iran via the cloud may rely upon the authorization in 31 CFR § 560.540 to provide access to Iran, provided that such provider conducts due diligence based on information… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence