Frequently Asked Questions

166. OFAC’s SDN List contains a list of entities identified by OFAC as being the Government of Iran. Should U.S. persons now block the property and interests in property of those entities?

… Yes, U.S. persons should now block the property and interests in property of the Government of Iran entities appearing on the SDN List , unless OFAC has authorized the underlying transaction … … OFAC’s SDN List contains a list of entities identified by OFAC as being the… Read more

365. What is authorized with respect to brokerage services related to exports or reexports of agricultural commodities, medicine, or medical devices to Iran?

… or reexportation by U.S. persons of agricultural commodities, medicine, and medical devices to Iran, provided that the sale and exportation or reexportation itself is authorized by either … related to exports or reexports of agricultural commodities, medicine, or medical devices… Read more

856. How will transactions related to Iran’s participation in legal proceedings, including administrative, judicial, arbitral proceedings, and proceedings before international courts and tribunals, be treated for purposes of secondary sanctions to the extent that Iranian financial institutions or the Iranian financial sector sanctioned under Executive Order (E.O.) 13902 are involved?

… as transactions or activities related to the defense of individuals in legal proceedings in Iran brought by the Government of Iran, including any arrest, investigation, prosecution, or detention. Such permissible … List of Specially Designated Nationals and… Read more

607. What activity will become sanctionable on or after November 5, 2018 under E.O. 13846 or other authorities?

… including under provisions of E.O. 13846 and relevant statutory authorities: i. Sanctions on Iran’s port operators, and shipping and shipbuilding sectors, including on the Islamic Republic of Iran Shipping Lines (IRISL), South Shipping Line Iran… Read more

187. Does the GHRAVITY E.O. prohibit me from exporting technology to companies that do business with Iran or Syria?

… … This E.O. does not generally prohibit transactions involving persons that do business with Iran or Syria, unless the person has been designated pursuant to this order. You should consult … the GHRAVITY E.O. prohibit me from exporting technology to companies that do business… Read more

165. To what extent are U.S. persons expected to conduct enhanced due diligence to determine if transactions contain a Government of Iran interest?

… requires U.S. persons to block all property and interests in property of the Government of Iran, unless otherwise exempt or authorized by OFAC. Please contact the OFAC Compliance Hotline , … for guidance regarding entities that you suspect are owned or controlled by the… Read more

174. What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “owned or controlled by the government of a foreign country,” “food, medicine, and medical devices,” “foreign financial institution,” “Iranian financial institution,” “significantly reduced,” and “whether the price and supply of petroleum and petroleum products produced in countries other than Iran is sufficient”?

… Financial Sanctions Regulations (IFSR), which implement section 104(c) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), identify factors to be used in … the following: The holding of nostro, vostro, or loro accounts for or with the Central Bank of… Read more

319. Does the GL for medical devices authorize the exportation or reexportation of these items to all entities in Iran?

… ( ITSR ) authorizes exports or reexports of certain medical devices to most entities in Iran, it does not authorize exports or reexports to military, intelligence, or law enforcement … medical devices authorize the exportation or reexportation of these items to all entities in… Read more

364. Who can apply for a specific license if an export or reexport to Iran is not authorized by general license?

… or -controlled foreign entity may apply for a specific license for the export or reexport to Iran of agricultural commodities excluded from the scope of the agricultural commodities general … such as live animals. … Who can apply for a specific license if an export or reexport to… Read more

150. Where can I find a list of Islamic Revolutionary Guard Corps (IRGC) affiliates and Iran-linked financial institutions “blocked pursuant to the International Emergency Economic Powers Act (IEEPA)”?

… 150 … The list of blocked IRGC affiliates and blocked Iran-linked financial institutions is dynamic and is based on the identity of “designated” … listings of designated IRGC entities will be followed by the tag [IRGC]; those of designated Iran-linked financial… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence