Frequently Asked Questions

296. Will the provision of bunkering services to a non-Iranian vessel carrying non-sanctionable goods to or from Iran be subject to sanctions?

296 … If a non-Iranian vessel is transporting non-sanctionable goods to or from Iran, the bunkering of that non-Iranian vessel in a country other than Iran — and related payments for these bunkering services — will not be subject to sanctions, only if (1) the transaction either does not involve U.S… Read more

205. I want to support non-governmental organizations (NGOs) that help the Syrian people. How can I do this while staying in compliance with sanctions?

205 … U.S. persons may donate funds to and raise funds on behalf of U.S. and third-country NGOs that engage in authorized activities in Syria (please see § 542.516 of the Syrian Sanctions Regulations for the full list of authorized activities). U.S. persons can also donate humanitarian goods like… Read more

232. As a U.S. person, can I send financial donations directly to Syria in support of charitable activities under the Syria NGO General License at § 542.516 of the Syrian Sanctions Regulations (SySR)?

232 … No. Without a specific license, U.S. persons are not permitted to transfer financial donations directly to Syria or to NGOs in Syria. If you wish to donate funds in support of humanitarian work in Syria, you may do so by giving funds to U.S. or third-country NGOs to support non-commercial… Read more

345. How can U.S. companies arrange for payment from Iran for exports authorized under 31 CFR § 560.540?

345 … In general, the payment requirements under 31 CFR § 560.540 are the same as for all other general licenses under the Iranian Transactions and Sanctions Regulations ( ITSR ). Section 560.540(c) of the ITSR provides that U.S. depository institutions or U.S. registered brokers or dealers in… Read more

691. Will the provision of bunkering services to a non-Iranian vessel carrying sanctionable goods to or from Iran be subject to sanctions?

691 … If a non-Iranian vessel is transporting sanctionable goods to or from Iran (including, but not limited to, petroleum, petroleum products, or petrochemical products from Iran; goods used in connection with the automotive sector of Iran; or iron, iron products, aluminum, aluminum products,… Read more

692. Will the provision of bunkering services for an Iranian vessel be subject to sanctions?

692 … Section 1244(d)(1) of IFCA makes sanctionable knowingly selling, supplying, or transferring to or from Iran significant goods or services used in connection with Iran’s energy, shipping, or shipbuilding sectors. (See FAQ 289 above for an interpretation of “significant.”) The provision of… Read more

297. Are there any exceptions to the sanctions provisions of section 1244 of IFCA?

297 … The following transactions are excepted from the provisions of section 1244 of IFCA . a. 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… Read more

346. What kind of due diligence is required for the exportation of fee-based services, software, or hardware authorized by 31 CFR § 560.540?

346 … Due diligence programs should be tailored to the particular risks encountered by exporters. As a general matter, companies selling fee-based services, software, or hardware authorized by 31 CFR § 560.540 should undertake reasonable, risk-based measures designed to ensure that they do not… 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 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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence