Frequently Asked Questions

315. Will routine payments or fees be subject to sanctions if they are made to a person determined to be a port operator in Iran and if the vessel is carrying non-sanctioned goods?

315 … Any company involved in loading or unloading cargo in Iran should exercise great caution to avoid engaging in transactions with entities designated by the United States, including the Tidewater Middle East Co. which was designated for its involvement in Iran’s proliferation of weapons of mass… Read more

298. For purposes of IFCA, what materials are considered graphite, raw or semi-finished metals?

298 … For purposes of IFCA , we anticipate that regulations to be promulgated will define graphite, raw or semi-finished metals described in section 1245(d) of IFCA to include steels; aluminum metal and its alloys; base metals of single or complex borides of titanium; beryllium metal and its alloys… Read more

347. Are there any restrictions as to the use of the Farsi language in authorized advertising or software?

347 … U.S. sanctions on Iran do not impose any restrictions as to the use of the Farsi language. See FAQ 337 . Date Updated: May 16, 2024 … Are there any restrictions as to the use of the Farsi language in authorized advertising or …

299. For purposes of IFCA, what are considered precious metals?

299 … For purposes of IFCA , we anticipate that regulations to be promulgated will define the term “precious metals” to include silver (including silver plated with gold or platinum, unwrought or in semi-manufactured forms, or in powder form); gold (including gold plated with platinum, unwrought or… Read more

370. What do the prohibitions in Directives 1 and 2 mean? Are they blocking actions?

370 … The sectoral sanctions imposed on specified persons operating in sectors of the Russian economy identified by the Secretary of the Treasury were done under Executive Order 13662 through Directive s issued by OFAC pursuant to its delegated authorities. Directive 1, as amended on September 29,… 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?

300 … Pursuant to delegated authority, the Secretary of State issues periodic reports pursuant to section 1245(e) of IFCA 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… 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?

301 … A FFI , prior to conducting or 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 undertake due diligence to ensure that the transaction does not involve the… Read more

302. Are there any exceptions to section 1245 of IFCA?

302 … A person will not be subject to sanctions under section 1245 of IFCA if a determination is made by the Department of the Treasury or the Department of State, as appropriate, that the person has established and enforced official policies, procedures, and controls to ensure that the person does… Read more

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

303 … A number of insurance activities are subject to sanctions under IFCA , including knowingly providing insurance, reinsurance, or underwriting services 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… Read more

652. Is it permissible for mutual funds and exchange traded funds (collectively, “funds”) that are U.S. persons to buy, sell, or otherwise engage in transactions related to debt, equity, or other holdings in an entity that appears on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), or of an entity owned 50 percent or more, individually or in the aggregate, by an individual or entity on the SDN List?

652 … No. A fund that is a U.S. person may not buy, sell, or otherwise engage in transactions related to debt, equity, or other holdings in blocked persons and must block such holdings, unless authorized by OFAC via general or specific license. A U.S. fund that contains such blocked holdings… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence