Frequently Asked Questions

292. What are the implications of IFCA on the provision of humanitarian goods to the people of Iran?

… transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran, as set out in more detail in Q&As 297 and 304 . … What are the implications of IFCA on the provision of humanitarian goods to the people of Iran? … transactions… 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

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

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

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 … My bank… Read more

1089. Can persons seeking to export software, services, or hardware to Iran in support of internet freedom apply for a specific license from OFAC if the export is not authorized by 31 CFR § 560.540?

… Yes, persons seeking to export software, services, or hardware to Iran or conduct other activities in support of internet freedom in Iran that are not exempt transactions or authorized by the general license in 31 CFR § 560.540 or … Can persons seeking to export… Read more

118. I have a client that is in Iran to visit a relative. Do I need to restrict the account?

… No. As long as you are satisfied that the client is not ordinarily resident in Iran, then the account does not need to be restricted. See FAQ 37 . … I have a client that is in Iran to visit a relative. Do I need to restrict the account? … No. As long as you are… Read more

605. How does E.O. 13846 relate to various Iran-related statutes?

… States of persons determined to have engaged in the transfer of goods or technologies to Iran that are likely to be used by the GOI or any of its agencies or instrumentalities to commit serious human rights abuses against the people of Iran or the provision of… Read more

823. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions or activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) that U.S. persons would be authorized to engage in under General License No. 8A (GL 8A)?

… No. Non-U.S. persons generally do not risk exposure under U.S. secondary sanctions relating to Iran for engaging in the sale of agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in… Read more

455. Is the provision of routine goods and services by non-U.S. persons to diplomatic missions of the Government of Iran located outside the United States sanctionable under U.S. law?

… for the conduct of the official business of the diplomatic missions of the Government of Iran located outside the United States or for the personal use of the employees of the missions, … Persons (other than any political subdivision, agency, or instrumentality of the Government… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence