Frequently Asked Questions

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

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

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?

… 1089 … 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 … Date Updated: May 16,… Read more

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 … Nationals… Read more

254. What does section 504 of the TRA do?

… States if they knowingly engage in significant financial transactions with the Central Bank of Iran (“CBI”) or a designated Iranian financial institution, unless an NDAA exception, such as the … facilitate bilateral trade in goods or services between the country granted the… Read more

258. What is meant by the TRA section 504’s requirement that bilateral trade consist of trade in goods and services between the country with primary jurisdiction over the foreign financial institution (FFI) and Iran?

… 258 … OFAC interprets bilateral trade between Iran and the country with primary jurisdiction over the FFI to mean trade in only those goods or … with primary jurisdiction over the FFI conducting or facilitating the transaction, or (ii) Iran (for purposes of the… Read more

263. Who can receive payments from funds credited to a RECIPIENT ACCOUNT or SPECIAL PURPOSE ACCOUNT?

… payment (e.g., the manufacturer or service provider) for goods or services being exported to Iran must be – (i) a citizen, national, or permanent resident of the country with primary … accounts. Furthermore, the person receiving such payment may not be - (i) the Government of… Read more

825. How can parties participate in the Swiss Humanitarian Trade Arrangement (SHTA) to export humanitarian goods to Iran?

… Regulations, 31 C.F.R. part 560 (ITSR), when conducting exports of humanitarian goods to Iran. Certain exports and sales of humanitarian goods to Iran are authorized pursuant to sections 560.530, 560.532, and 560.533 of the ITSR. In addition, … for such… Read more

487. Are goods that are unloaded from a ship in an Iranian port, put on a truck, and driven out of the boundaries of the port or place of unloading considered to be Iranian-origin goods?

… 487 … Yes. These goods have otherwise come in contact with Iran and thus do not fall within the carve-out to the definition of Iranian-origin goods or goods … 560.306 (b)(2) of the ITSR . However, if these goods are being exported or reexported to Iran under an… Read more

644. Is an entity that is owned or controlled by a U.S. person and established or maintained outside the United States (a “U.S.-owned or -controlled foreign entity”) required to apply restrictions akin to blocking on the property or interests in property of persons subject to section 560.211 of the ITSR?

… from knowingly engaging in any transaction, directly or indirectly, with the Government of Iran or any person subject to the jurisdiction of the Government of Iran that would be prohibited by the ITSR if engaged in by a U.S. person or in the United States. …

Frequently Asked Questions

Office of Terrorism and Financial Intelligence