Frequently Asked Questions

598. What does E.O. 13846 do?

… 13846, these measures include implementing authority for and additional tools related to: the Iran Sanctions Act of 1996, as amended (ISA) , the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010, as amended (CISADA) , the Iran… Read more

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 … States, including the Tidewater Middle East Co. which was designated for its involvement in Iran’s… Read more

645. How will the re-imposition of sanctions on November 5, 2018 impact the provision of specialized financial messaging services to Iranian financial institutions?

… on the provision of specialized financial messaging services set forth in section 220 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA) snap back in full. This authority … to the Central Bank of Iran or Iranian financial institutions… Read more

641. If a country with primary jurisdiction over a foreign financial institution did not receive a significant reduction exception (SRE) under section 1245(d)(4)(D) of the NDAA 2012, can funds currently held at the foreign financial institution in that country on behalf of the Central Bank of Iran be used to facilitate humanitarian trade with Iran?

… Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran involving the Central Bank of Iran are excepted from the relevant sanctions under section 1245(d)(2) of the NDAA 2012 and … held at the foreign financial institution… Read more

37. My bank operates accounts for individuals living in Iran. OFAC has told us that these accounts cannot be operated. Does this mean that the accounts are blocked?

… the accounts are restricted. The Iranian sanctions prohibit the export of goods or services to Iran. By operating an account for an individual or company in Iran, the bank would be exporting services to that person or entity in violation of the Iranian … her… Read more

669. Does E.O. 13871 expand upon existing sanctions relating to trade with Iran in certain raw and semi-finished metals, such as aluminum and steel?

… section 1245 of IFCA on the sale, supply, or transfer, directly or indirectly, to or from Iran of certain materials, including raw and semi-finished metals such as aluminum and steel, as … or (C) of IFCA. In addition, E.O. 13871 explicitly targets the iron and copper sectors of… Read more

483. How does an exporter determine which medical devices need to be specifically licensed by OFAC for exportation or reexportation to Iran?

… Devices Requiring Specific Authorization , which is maintained on OFAC’s website, on the Iran Sanctions page . An exporter must obtain a specific license from OFAC to export or reexport any medical device on that list to Iran. An exporter must also obtain a… Read more

609. What does E.O. 13846 do with respect to the sanctions on Iran’s automotive sector?

… for certain transactions, on or after August 7, 2018, for the sale, supply, or transfer to Iran of significant goods or services used in connection with Iran’s automotive sector. … What does E.O. 13846 do with respect to the sanctions on Iran’s …

256. What transactions are impacted by section 504 of the TRA as it amends section 1245 of the National Defense Authorization Act (NDAA) for Fiscal Year 2012?

… conducted or facilitated by a foreign financial institution (FFI) with the Central Bank of Iran (CBI) on or after November 5, 2018 or with a designated Iranian financial institution may be … (ii) the significant financial transaction is for bilateral trade only, and any funds… Read more

829. Following the Secretary of State’s announcement on May 27, 2020 that he will be ending certain Iran nuclear-related waivers, will there be a wind-down period for persons engaged in activity permitted by these waivers?

… waivers associated with the Arak reactor modernization redesign, the transfer into Iran of enriched uranium for the Tehran Research Reactor, and the transfer out of Iran of certain nuclear fuel scrap and of spent research reactor fuel will have a final, 60-day …… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence