Frequently Asked Questions

290 … There is no general exception for payments, sales, deliveries, or transfers arising out of contracts entered into prior to July 1, 2013, on or after which date certain activities become sanctionable under the  Iran Freedom and Counter-Proliferation Act of 2012 (IFCA). The assessment of… Read more

292 … IFCA generally excepts from sanctions 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 …

225 … The United States has sanctioned the Syrian government, including the Central Bank of Syria, senior Syrian government officials, and individuals and entities supporting the Assad regime and/or responsible for human rights abuses in Syria, in order to reinforce the President’s call that Bashar… Read more

293 … We anticipate that regulations to be promulgated will define “energy sector of Iran” to include activities involving the exploration, extraction, production, refinement, or liquefaction of petroleum, natural gas, or petroleum products in Iran. (See also discussion of activities involving… Read more

229 … No. You may send U.S.-origin food or medicine to Syria without a specific license from OFAC. The Department of Commerce, Bureau of Industry and Security (“BIS”), which maintains jurisdiction over the export of most items to Syria, does not require a license for the export of U.S.-origin food… Read more

231 … Yes.  U.S. NGOs may provide services to Syria in support of humanitarian projects in Syria as authorized by § 542.516 of the Syrian Sanctions Regulations.  NGOs carrying out activities funded by the U.S. government, as described in § 542.522, or international organizations, as described in §… Read more

135 … Yes. The new Syria Executive order, Executive Order 13582, does not prohibit U.S. persons from engaging in transactions ordinarily incident to travel to or from any country, including importation of accompanied baggage for personal use, maintenance within any country including payment of… Read more

1172 … No.  The processing, clearing, or sending of payments related to Russian metals by a U.S. bank on behalf of non-U.S. persons is not prohibited by the Metals Services Determination where the bank:  (1) is operating solely as an intermediary; and (2) does not have any direct relationship with… Read more

1173 … User authentication services are services used to login or verify the identity of a user to a particular software or service, such as a user identification account often used to login to email, mobile app stores, or other activities authorized by 31 CFR § 560.540 . … What are “user… Read more

1174 … Persons providing web hosting services authorized pursuant to 31 CFR § 515.578 may reasonably rely on information provided to them by their customers in the ordinary course of business, unless they know or have reason to know their provision of web hosting services is for the promotion of… Read more