Frequently Asked Questions

488. Are goods that are unloaded from a ship in an Iranian port, moved within the boundaries of the port, and loaded onto a second ship en route to a destination outside of Iran, without ever leaving the port considered to be Iranian-origin goods?

… No, provided that they have not otherwise come in contact with Iran. … the boundaries of the port, and loaded onto a second ship en route to a destination outside of Iran, without ever leaving the port considered to be Iranian-origin goods? … No, provided that… Read more

614. What does E.O. 13846 do with respect to Iran’s energy, petroleum, and petrochemical sectors?

… sale, transport, or marketing of petroleum, petroleum products, or petrochemicals from Iran, with the aim of deterring Iran or any other country or institution from establishing workaround payment mechanisms for the … supply, or transfer to or from Iran… 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. … from… Read more

640. What does the November 5, 2018 amendment to the ITSR do?

… of, the purchase or acquisition of U.S. bank notes or precious metals by the Government of Iran, or (ii) on or after November 5, 2018, materially assisted, sponsored, or provided … Iranian Oil Company (NIOC), the Naftiran Intertrade Company (NICO), or the Central Bank of … Read more

172. How does Executive Order 13599, “Blocking Property of the Government of Iran and Iranian Financial Institutions,” and the blocking of all Iranian financial institutions affect the financial sanctions provisions in CISADA? Do CISADA sanctions now apply to financial transactions with any Iranian financial institution?

… The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) applies to transactions with only those Iranian financial institutions that are designated in connection with Iran’s WMD or terrorism activities and are denoted on OFAC’s List of… Read more

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

… or U.S. registered brokers or dealers in securities may process transfers of funds from Iran or for or on behalf of a person in Iran that are in furtherance of a transaction authorized under 31 CFR § 560.540, provided the … How can U.S. companies arrange for… Read more

606. What activity will become sanctionable on or after August 7, 2018 under E.O. 13846 or other authorities?

… dollar banknotes by the GOI (see, e.g., subsection 1(a)(i) of E.O. 13846); ii. Sanctions on Iran’s trade in gold or precious metals (see, e.g., subsection 1(a)(i) of E.O. 13846 and … debt (see, e.g., section 5 of E.O. 13846 and subsection 213(a) of TRA); and vi. Sanctions on… Read more

824. What is the Swiss Humanitarian Trade Arrangement (SHTA)?

… institutions in establishing payment mechanisms to facilitate humanitarian exports to Iran that are subject to enhanced due diligence. While the United States maintains broad exceptions and authorizations for the conduct of humanitarian trade with Iran, this… Read more

192. Why was this authority needed?

… foreign persons determined to have violated or attempted to violate U.S. sanctions on Syria or Iran, or to have facilitated deceptive transactions on behalf of persons subject to those … may use this authority where it appears that a foreign person violated U.S. sanctions on… Read more

266. Does the November 8, 2012 designation of National Iranian Oil Company (NIOC) under E.O. 13382 impact the scope of permissible transactions by foreign financial institutions (FFIs) in significantly reducing countries?

… Yes. On September 24, 2012, NIOC was identified as an agent or affiliate of Iran’s Islamic Revolutionary Guard Corps (“IRGC”) under section 312 of the TRA , and designated … E.O. 13382 for providing services and support to the IRGC. Accordingly, the Comprehensive Iran… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence