| Frequently Asked Questions (Sorted By Question) |
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| 1 |
What is OFAC and what does it do? |
| 2 |
How long has OFAC been around? |
| 3 |
What does one mean by the term "prohibited transactions"? |
| 4 |
Are there exceptions to the prohibitions? |
| 5 |
How do I determine if I have a valid OFAC match? |
| 6 |
Where can I find the specific details about the embargoes? |
| 7 |
Can I get permission from OFAC to transact or trade with an embargoed country? |
| 8 |
What must I do to get permission to trade with an embargoed country? |
| 9 |
What do you mean by "blocking?" |
| 10 |
What countries do I need to worry about in terms of U.S. sanctions? |
| 11 |
Who must comply with OFAC regulations? |
| 12 |
How much are the fines for violating these regulations? |
| 13 |
Is there a mechanism for a company to report its past undetected violations of OFAC regulations for completed transactions? Is any type of "amnesty" available for inadvertent failure to comply prior to the company becoming aware of the OFAC regulations? |
| 14 |
Can I regard previously issued and published opinion letters, regulatory interpretations, or other statements as guidance for my transactions? |
15 |
Can OFAC change its previously stated, non-published interpretation or opinion without first giving public notice? |
| 126 |
I tried to ship a package and it was returned to me "due to OFAC sanctions." Why? |
| 127 |
I tried to ship a package and it was "blocked" by the shipping company "due to OFAC sanctions." Why? And how can I get the package unblocked? |
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| Questions about Specially Designated Nationals (SDNs) |
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| 18 |
What is an SDN? |
| 19 |
How do I get a copy of this list? |
| 20 |
How often is the SDN list updated? |
| 21 |
How do I know what specific changes have been made to OFAC's SDN list? |
| 22 |
Does OFAC maintain or can it create a country-by-country list of SDNs? |
| 23 |
What do I do if I have a match to the SDN list? |
| 24 |
What is the Control list? Who do I call about the Control list? What is the difference between the Control list and OFAC's SDN list? |
| 122 |
What are weak aliases (AKAs)? |
| 123 |
Where can I find weak aliases (AKAs)? |
| 124 |
Am I required to screen for weak aliases (AKAs)? |
| 125 |
Will I be penalized for processing an unauthorized transaction involving a weak alias (AKA)? |
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| Questions from Financial Institutions |
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| 25 |
Does OFAC itself require that banks set up a certain type of compliance program? |
| 26 |
How do I get the OFAC Starter Kit? |
| 27 |
What do I need to do to comply? Do I have to buy expensive software? |
| 28 |
How often do I need to scan my customer database for SDNs? |
| 29 |
How do I setup a compliance program for my bank? |
| 30 |
How do I know if my compliance program is adequate? |
| 31 |
What are the features and benefits that banks should be looking for when selecting an OFAC compliance software package? |
| 32 |
How do I block an account or a funds transfer? |
| 33 |
How much interest do I have to pay on the blocked funds? |
| 34 |
Can my bank deduct service charges from the account? |
| 35 |
Do all OFAC programs involve blocking transactions? |
| 36 |
I understand blocking a transaction, but what is meant by rejecting a transaction? When should a transaction be rejected rather than blocked? |
| 37 |
My bank operates accounts for individuals living in Iran. OFAC has told us that these accounts cannot be operated. Does this mean that the accounts are blocked? |
| 38 |
Are U-Turn payments for Iran still permitted? |
| 118 |
I have a client that is in Iran to visit a relative. Do I need to restrict the account? |
| 39 |
What do I do if I have a blocked account that needs to be escheated to the state? |
| 40 |
If my financial institution receives a wire going to an embassy in a sanctioned country, can we process the transaction? |
| 41 |
Should an institution tell its customer that it blocked their funds, and, if so, how does the institution explain it to them? |
| 42 |
What do I do if a person tries to open an account and the person's name is on OFAC's SDN list? Do I open the account and then block the funds? |
| 43 |
Does a financial institution need to scan names against OFAC's list of targets upon account opening or can it wait for 24 hours to receive a report from its software vendor on whether or not there is a hit? |
| 44 |
Is there a dollar limit on which transactions are subject to OFAC regulations? |
| 45 |
Does my bank need to check the OFAC list when selling cashier's checks and money orders? In the case of cashier's checks, do I need to check both the purchaser and the payee? As a mortgage lender, do I need to check both the purchaser and the seller's name against the SDN list? |
| 46 |
If a loan meets underwriting standards but is a true "hit" on the OFAC list, what do we use as a denial reason on the adverse action notice? |
| 47 |
Through corporate giving programs, many banks contribute toward charities and other non-profits. To what extent does a bank need to review the recipients of these gifts or the principals of the charities? |
| 48 |
I just received an interdiction "alert." What do I do? |
| 49 |
When a transaction is rejected or blocked, I have ten days to report it. Do I have to do it in writing or can I call OFAC Compliance and report it that way? |
| 50 |
Is there a requirement for annual reporting of blocked property? Is there a required format? |
| 51 |
How do I apply for a license to get my money unblocked? |
| 52 |
Can U.S. financial institutions open correspondent accounts for Iraqi financial institutions, or process funds transfers to and from Iraqi financial institutions? |
| 53 |
How do I differentiate between an "inquiry" and a "payment instruction" when a customer wants to send a wire transfer to a sanctioned party or country? |
| 54 |
I have an account with a W-8 showing an address in Iran. Is the account automatically restricted? |
| 95 |
Does a financial institution have the obligation to screen account beneficiaries for compliance with OFAC regulations? |
| 116 |
On February 14, 2008, OFAC issued guidance stating that the property and interests in property of an entity are blocked if the entity is owned, directly or indirectly, 50% or more by a person whose property and interests in property are blocked pursuant to an Executive Order or regulations administered by OFAC. We act as an intermediary bank in wire transfers between other banks. Does OFAC expect banks that are acting as financial intermediaries to research non-account parties that do not appear on the SDN List, but are involved with or referenced in transactions that are processed on behalf of correspondents? |
| Questions from Exporters & Importers |
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| 55 |
Does OFAC have an exporter assistance phone line? |
| 56 |
What is the difference between the SDN List and the Commerce Department's List of Denied Parties? Why can't they be integrated into one list? |
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| Questions related to NGO Registration Numbers |
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| 57 |
How do I get an NGO registration number? |
| 58 |
What are the chances that my application will be approved? |
| 59 |
Do I need a registration number or license to donate goods? |
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| Questions from the Insurance Industry |
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| 61 |
State insurance statutes regulate an insurer's ability to withhold claim payments, cancel policies or to decline to enter into policies. In some cases, insurers must commit an ostensible violation of state insurance regulations to comply with OFAC regulations. Does OFAC have a position as to whether OFAC regulations preempt state insurance regulations in this context? |
| 62 |
At what point must an insurer check to determine whether an applicant for a policy is an SDN? |
| 63 |
What should an insurer do if it discovers that a policyholder is or becomes an SDN--cancel the policy, void the policy ab initio, non-renew the policy, refuse to pay claims under the policy? Should the claim be paid under a policy issued to an SDN if the payment is to an innocent third-party (for example, the injured party in an automobile accident)? |
| 64 |
A workers' compensation policy is with the employer, not the employee. Is it permissible for an insurer to maintain a worker's compensation policy that would cover a person on the SDN List, since the insurer is not transacting business with the SDN, but only with his/her employer? |
| 65 |
How frequently is an insurer expected to scrub its databases for OFAC compliance? |
| 66 |
Is it sufficient if my company screens life insurance policies only prior to policy issuance? |
| 67 |
If my policyholder, who is a U.S. person, requests a change of beneficiaries and designates a cousin living in Cuba as a beneficiary under the life insurance policy, what shall I do? |
| 68 |
If my screening efforts uncover a policyholder who became an SDN after policy issuance, can I notify the policyholder that the policy is “blocked”? |
| 69 |
In my letter to the policyholder whose policy is “blocked,” may I also instruct the policyholder not to send any more premium or that we will not accept additional premium under this account? |
| 102 |
How can an insurer participate in worldwide insurance markets through global insurance policies if, by definition, coverage extends to potential countries? |
| 103 |
What if the commercial setting and/or market circumstances of a global insurance policy does not permit the use of an OFAC exclusion such as the one noted above? |
| 104 |
Can an insurer offer global travel insurance and worldwide travel assistance without violating U.S. sanctions? |
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| 70 |
What Is This OFAC Information On My Credit Report? |
| 71 |
How Can I Get The OFAC Alert Off My Credit Report? |
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| 72 |
Can I send money to a sanctioned country using a third-country company's website? Can I buy gifts for someone in a sanctioned country over the internet? The websites tell me that it's o.k. because they themselves are not sanctioned parties. |
| 73 |
My company provides money remittance and account services via the Internet. Does OFAC have any compliance guidance for this type of business? |
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| 74 |
What is a license? |
| 75 |
Do I have to fill out a particular form to get a license to engage in a transaction? |
| 128 |
What information is needed from applicants requesting a license to sell real property located in Iran to transfer the proceeds from the sale to the United States? |
| 76 |
Can I appeal a denial of my license application? |
| 77 |
How can I find out the status of my pending license application? |
| 78 |
What agencies other than Treasury review OFAC license applications and what are the roles of these other agencies? |
| 94 |
Is a license required to enter into an over flight permit agreement with the Cuban Civil Air Authority, even if there is no cost? |
| 97 |
What format options are permitted for submitting license applications pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA)? |
| 98 |
How should I present my TSRA license application? |
| 99 |
What is the procedure for submitting multiple copies of the same TSRA license application? |
| 100 |
If I am submitting multiple TSRA license applications at the same time, should I send them under a single cover letter? |
| 101 |
Should I send a sample of the proposed export product as an attachment to my TSRA license application? |
| 117 |
I hold a specific license to sell agricultural goods, medicine, or medical devices to Iran. The terms of the license allow me to accept a letter of credit issued by a bank in Iran which has not been named a Specially Designated National under any of the programs administered by OFAC. The license, however, also states that a U.S. financial institution may not advise, confirm or otherwise deal in that credit. How am I supposed to know if/when a letter of credit has been issued for my sale and how do I get paid? My bank accounts are all at U.S. financial institutions. |
| 119 |
The US exporter has a valid, one-year specific license issued pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA) by the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC), to enter into contracts during the one-year period of the license for the export/reexport of medical devices and to ship these medical devices within the 12-month period beginning on the date of signing of the contract (the "validity period"). Out of the box, the medical device has a defective component, or a component breaks within the validity period of the license. Can the US exporter send a replacement part pursuant to its valid OFAC license as a transaction that is ordinarily incident and necessary to the sale of the medical device as a whole? |
| 120 |
The US exporter exports a medical device pursuant to a valid OFAC TSRA license. After a few years, some components break. The US exporter wants to send replacement parts. What is the US exporter required to do? |
| 121 |
The US exporter has a valid OFAC TSRA license to export/reexport a medical device. The US exporter has exported a medical device pursuant to this license. The medical device breaks during the validity period of the license. Can the US exporter import the item back into the US pursuant to the original license? |
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| Technology Questions |
^ TOP |
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| 79 |
Does OFAC provide its SDN List in a format that can be easily imported into a database? |
| 80 |
Does OFAC provide its SDN List in a spreadsheet format? |
| 105 |
OFAC says it has updated its SDN list, but when I download the appropriate SDN files from the OFAC website, they appear to be out-of-date. Where can I get the latest SDN information? |
| 81 |
What is the delimiter in OFAC's delimited files? |
| 82 |
Does OFAC have a web-based SDN search engine? |
| 83 |
How are OFAC's delimited files structured? |
| 84 |
Does OFAC maintain its files in locations other than on its website? |
| 85 |
Is there a version of the delimited archive that works with UNIX? |
| 86 |
Does OFAC have an email service that will notify me when there are updates to the SDN list? |
| 87 |
Your FTP site has gone offline. Who should I contact to remedy this problem? |
| 88 |
I am a systems administrator looking to design an automated process that will download the SDN list without human intervention. How can I do this given that changes to the SDN list can be sporadic? |
| 89 |
I am a database administrator at a bank and responsible for keeping my company's SDN data current. Is the SDN list comprehensive or do I need to download some kind of supplement to the list every time there is an update? |
| 90 |
Do you offer the OFAC Financial Operations Bulletin in a delimited format? |
| 91 |
I am looking for the terrorist list on your web site so I can bring my company in compliance with U.S. law. Where can I find this list? |
| 92 |
I'm a subscriber to OFAC's e-mail notification services. For some reason I have stopped receiving the broadcast messages when OFAC updates its website. Why is this? |
| 93 |
I recently attempted to subscribe to one of OFAC's e-mail list services and I have not yet received my confirmation e-mail. Why is this? |
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| Questions Regarding Private Relief Efforts in Somalia |
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| 129 |
Can I make a private donation to a charity that is delivering humanitarian assistance in Somalia? |
| 130 |
Can my organization provide humanitarian assistance in Somalia? |
| 131 |
What if, in delivering humanitarian assistance, my organization unintentionally provides food or medicine to members of al-Shabaab? |
| 132 |
What if, in delivering humanitarian assistance, my organization unintentionally provides cash to members of al-Shabaab? |
| 133 |
I have heard that certain U.S. humanitarian assistance organizations are exempted from the prohibition on making certain cash payments to al-Shabaab. Is that correct? |
| 134 |
I have family members or friends in Somalia and would like to send remittances to them. Can I do that without violating OFAC sanctions? |
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| Questions Regarding Syria |
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| 135 |
Are travel-related transactions permissible under the new Syria Executive order 13582? |
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Questions Related to OFAC Syria General License No. 4: Exports or reexports to Syria of items subject to the Export Administration Regulations: |
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| 136 |
What does the term "items" cover, and what is meant by items subject to the Export Administration Regulations? |
| 137 |
Regarding OFAC Syria General License No. 4A, will I need a specific license from OFAC to export or reexport food or medicine to the Government of Syria? |
| 138 |
Does General License No. 4A authorize U.S. persons to export or reexport from a third country to Syria or the Government of Syria a foreign-made item with either no U.S. content or de minimis U.S. content? |
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OFAC Syria General License No. 6: Personal Remittances |
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| 140 |
May I continue to send money to family or friends in Syria? |
| 141 |
May I send personal remittances through the Commercial Bank of Syria, the Syrian-Lebanese Commercial Bank, or the Syria International Islamic Bank (SIIB) to family or friends in Syria? |
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General License No. 11: Authorizing Services in Support of Nongovernmental Organizations’ Activities in Syria |
| 205 |
Who is authorized to send money to support certain nongovernmental organizations’ activities? |
| 206 |
As an individual, may I transfer funds directly to Syria in support of authorized NGO activities under General License No. 11? |
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| Questions Regarding the Central Bank of South Sudan |
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| 142 |
Is the new Bank of South Sudan still considered to be part of or linked to the Central Bank of Sudan or the Government of Sudan? |
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| Questions Regarding Activities in the Republic of South Sudan |
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| 143 |
Can I export equipment for use in South Sudan’s oil sector? |
| 144 |
Can I transship equipment through Sudan to use in South Sudan? |
| 145 |
Do I need any additional authorization from OFAC to engage in particular activities related to South Sudan’s oil sector, such as paying pipeline or port fees? |
| 146 |
Can I participate in the refining of Southern Sudanese crude oil in refineries located in Sudan? |
| 147 |
Does this mean I can do business in Sudan’s oil sector now? |
| 148 |
Can I use a bank that is owned by the Government of Sudan to facilitate a payment for oil-related activities in South Sudan? |
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| Questions Regarding CISADA (Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010) |
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| 149 |
What activities by foreign financial institutions can subject them to CISADA sanctions? |
| 150 |
Where can I find a list of Islamic Revolutionary Guard Corps (IRGC) affiliates and Iran-linked financial institutions “blocked pursuant to IEEPA”? |
| 151 |
How do the Iranian Financial Sanctions Regulations define “U.S. financial institutions”? |
| 152 |
How do the Iranian Financial Sanctions Regulations define “foreign financial institutions”? |
| 153 |
How do the Iranian Financial Sanctions Regulations (IFSR) define the term “knowingly”? |
| 154 |
How does the Treasury Department determine whether a transaction or financial service is “significant” for purposes of the Iranian Financial Sanctions Regulations? |
| 155 |
When are the prohibitions and strict conditions on foreign financial institutions’ correspondent accounts or payable-through accounts in the United States effective? |
| 156 |
How will U.S. and foreign financial institutions know that the Treasury Department has made such a finding? |
| 157 |
How will the Treasury Department enforce the Iranian Financial Sanctions Regulations (IFSR) with respect to U.S. entities? |
| 158 |
Can the application of any part(s) of the Iranian Financial Sanctions Regulations be waived by the Department of the Treasury? |
| 159 |
Where can I find the text of the Iranian Financial Sanctions Regulations? |
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| Questions Regarding Executive Order 13599 (Blocking Property of the Government of Iran and Iranian Financial Institutions) |
On February 5, 2012, the President signed Executive Order 13599 to implement section 1245(c) of the National Defense Authorization Act for Fiscal Year 2012, Public Law 112-81 (“NDAA”) and to take additional steps with respect to Iran. Effective as of 12:01 a.m. eastern standard time on February 6, 2012, the order blocks all property and interests in property of the Government of Iran (including the Central Bank of Iran), all Iranian financial institutions, and all persons determined by the Secretary of the Treasury, in consultation with the Secretary of State, to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to the order.
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| 160 |
Section 1 of E.O. 13599 blocks all property and interests in property of the Government of Iran, including the Central Bank of Iran, and of all Iranian financial institutions, that are in the United States, that come within the United States, or that come within the possession or control of U.S. persons (including overseas branches). Can you provide further clarification about this provision of E.O. 13599? |
| 161 |
If all property and interests in property of the Government of Iran, including the Central Bank of Iran, and of all Iranian financial institutions are blocked, can I conduct transactions involving the Government of Iran that have been previously authorized by OFAC? |
| 162 |
Are U.S. persons still required to comply with the Iranian Transactions Regulations? |
| 163 |
What are the differences and similarities between E.O. 13599 and the Iranian Transactions Regulations? |
| 164 |
The Iranian Transactions Regulations authorize U.S. depository institutions and U.S. registered brokers or dealers in securities to process transfers of funds to or from Iran if the transfer is a non-commercial, personal remittance. Are U.S. depository institutions and U.S. registered brokers or dealers in securities still authorized to process such payments to or from a Government of Iran-owned bank that is not otherwise designated pursuant to another part of 31 C.F.R. Chapter V? |
| 165 |
To what extent are U.S. persons expected to conduct enhanced due diligence to determine if transactions contain a Government of Iran interest? |
| 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? |
| 167 |
OFAC has granted my company a license under the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”) and the ITR. Can I continue to conduct the licensed transaction? |
| 168 |
OFAC has issued me a (non-TSRA) specific license related to Iran, or the Government of Iran. Can I continue to conduct the licensed transactions? |
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| Questions Regarding the NDAA (Section 1245 of the National Defense Authorization Act for Fiscal Year 2012) |
On December 31, 2011, the President signed into law the National Defense Authorization Act for Fiscal Year 2012, Public Law 112-81 (“NDAA”). Section 1245 of this statute requires the President to block the property and interests in property subject to U.S. jurisdiction of all Iranian financial institutions, including the Central Bank of Iran (“CBI”). It also aims to reduce Iranian oil revenues and discourage transactions with the CBI by providing for sanctions on foreign financial institutions that knowingly conduct or facilitate certain significant financial transactions with the CBI. Although the sanctions on foreign financial institutions authorized by section 1245 are similar to the financial sanctions under the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (22 U.S.C. 8513(c)) (“CISADA”) (i.e., prohibiting and/or imposing strict conditions on opening or maintaining correspondent accounts or payable-through accounts in the United States), there are differences in the scope and operation of the two statutes. |
| 169 |
What is the NDAA? |
| 170 |
What activities can trigger sanctions on a foreign financial institution under the NDAA? |
| 171 |
Does the NDAA repeal or amend Section 104(c) of CISADA? |
| 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? |
| 173 |
Are there any exceptions to the sanctions provisions in the NDAA? |
| 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”? |
| 175 |
What is the scope of “petroleum products” under the law? |
| 176 |
If oil is being provided as payment for an outstanding debt, is such a transfer considered a “financial transaction”? |
| 177 |
If the CBI is involved in providing settlement services for a transaction, or is otherwise acting solely as an intermediary in a transaction between a non-designated Iranian bank and a foreign financial institution, is the foreign financial institution deemed to be engaging in a transaction with the CBI? |
| 178 |
Are barter trades involving the CBI considered “financial transactions” under Section 1245? |
| 179 |
Does the definition of “significant financial transaction” exclude the passive holding of CBI reserves? Is the U.S. willing to give assurances that this will not be a basis for sanctions? |
| 180 |
Are payments made under contracts existing prior to the date of enactment of the NDAA statute (December 31, 2011) exempted from the definition of “significant transactions”? |
| 181 |
Will the U.S. refrain from sanctioning foreign financial institutions that receive funds from the CBI to repay loans? What if these loans were granted for projects that might be subject to the food, medicine, and medical device exemptions under the NDAA? |
| 182 |
Is there a difference between entities that have been designated by the United States Government for illicit conduct, such as proliferation of weapons of mass destruction or support for terrorism, and those that are being blocked under E.O. 13599? How can I tell which entities appear on the SDN List for which reasons? |
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| Questions Regarding Executive Order 13606 (the GHRAVITY E.O.) |
On April 22, 2012, the President signed Executive Order 13606 Blocking The Property And Suspending Entry into the United States of Certain Persons with Respect to Grave Human Rights Abuses by the Governments of Iran and Syria Via Information Technology (the “GHRAVITY E.O.”). Effective 12:01 a.m. eastern daylight time on April 23, 2012, the GHRAVITY E.O. blocks all property and interests in property of persons listed in its Annex, and all persons determined by the Secretary of the Treasury, in consultation with or at the recommendation of the Secretary of State, to meet the criteria in the order. |
| 183 |
Why did the President issue the GHRAVITY E.O.? |
| 184 |
What does the GHRAVITY E.O. do? |
| 185 |
What type of activities does the GHRAVITY E.O. target? |
| 186 |
How do I know that a person has been designated under the GHRAVITY E.O.? |
| 187 |
Does the GHRAVITY E.O. prohibit me from exporting technology to companies that do business with Iran or Syria? |
| 188 |
If I am a non-U.S. company that exports information and communications technology to Iran or Syria, will I be designated under the GHRAVITY E.O.? |
| 189 |
Would I need authorization from OFAC or BIS if I wanted to export goods or technology to persons blocked under the GHRAVITY E.O.? |
| 190 |
Are existing licenses issued by the U.S. Government involving persons designated under the GHRAVITY E.O. still valid? |
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| Questions Regarding Executive Order 13608 “Prohibiting Certain Transactions with and Suspending Entry into the United States of Foreign Sanctions Evaders with Respect to Iran and Syria” |
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| 191 |
What does Executive Order 13608 “Prohibiting Certain Transactions with and Suspending Entry into the United States of Foreign Sanctions Evaders with Respect to Iran and Syria” do? |
| 192 |
Why was this authority needed? |
| 193 |
What are the repercussions of an individual or entity being identified under Executive Order 13608? |
| 194 |
Are U.S. persons required to block the property of individuals and entities identified under Executive Order 13608? |
| 195 |
I am a financial institution. What do I do if I receive a wire transfer involving a listed party? |
| 196 |
I am a financial institution and I hold an account for a listed person. What do I do with the funds? |
| 197 |
What are U.S. persons obligated to do with property of a person listed under Exeutive Order 13608? |
| 198 |
May a U.S. person deal with an Executive Order 13608-listed person so long as the dealing does not involve Iran or Syria? |
| 199 |
How is an identification or listing under Executive Order 13608 different from a designation? |
| 200 |
How is this different from lists maintained by the Department of Commerce? |
| 201 |
May a U.S. person deal with a person listed under Executive Order 13608 in a transaction that was previously licensed by OFAC? |
| 202 |
What if the transaction is already underway? |
| 203 |
Can a U.S. person use a listed person to facilitate personal remittances to or from Iran or Syria? |
| 204 |
Will Treasury pursue an enforcement action before identifying or listing a person pursuant to Executive Order 13608.? |
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| Questions Related to Treasury CISADA Findings Against Elaf Islamic Bank and Bank of Kunlun |
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| 207 |
What were the criteria for this finding? How many other institutions were you looking at and why did you decide to take action against Elaf Islamic Bank and Bank of Kunlun? |
| 208 |
How are you defining “significant” transactions and financial services? |
| 209 |
What happens to the correspondent and payable-through accounts held by Elaf Islamic Bank and Bank of Kunlun in the United States? |
| 210 |
What are the consequences for a U.S. financial institution that maintains or opens a new correspondent or payable-through account for Elaf Islamic Bank or Bank of Kunlun? |
| 211 |
If a foreign financial institution continues to do business with Elaf Islamic Bank or Bank of Kunlun, could that lead to a CISADA finding against the other institution? |
| 212 |
Does this finding affect Elaf Islamic Bank’s or Bank of Kunlun’s branches or subsidiaries around the world? Does this finding affect any holding companies? |
| 213 |
Are United States financial institutions that do not hold correspondent or payable-through accounts for Elaf Islamic Bank or Bank of Kunlun required to block or reject transactions that otherwise involve Elaf Islamic Bank or Bank of Kunlun? |
| 214 |
What is the licensing process for U.S. financial institutions that need to conduct transactions in order to close correspondent or payable-through accounts with a foreign financial institution sanctioned pursuant to CISADA? |
| 215 |
What is the difference, in practical effect, between this and a designation under one of your other authorities, like E.O. 13382? |
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| Questions Related to Executive Order 13622, “Authorizing Additional Sanctions With Respect to Iran” |
On July 30, 2012, the President signed Executive Order 13622 to authorize additional sanctions with respect to Iran. Effective as of 12:01 a.m. Eastern Standard Time on July 31, 2012, the order provides additional sanctions authorities to the Secretary of the Treasury and the Secretary of State. The order builds, in part, on prior authorities set forth in the National Defense Authorization Act for Fiscal Year 2012 (“NDAA”) and in the Iran Sanctions Act of 1996, as amended (“ISA”). |
| 216 |
What does E.O. 13622 “Authorizing Additional Sanctions With Respect to Iran” do? |
| 217 |
Why was this authority needed? |
| 218 |
What constitutes a “significant” financial transaction under the new E.O. 13622? Is there a certain dollar threshold? |
| 219 |
Does E.O. 13622 mean that Iranian trade partners should no longer buy petroleum products from Iran? How will this affect exports of Iranian oil? |
| 220 |
Does E.O. 13622 mean you are designating NIOC and NICO? Can countries that have been excepted from NDAA sanctions still purchase oil through these companies without facing sanctions? |
| 221 |
E.O. 13622 targets transactions between foreign financial institutions and NIOC or NICO. What about a NIOC or NICO subsidiary? Are transactions with those entities also sanctionable under this E.O.? |
| 222 |
Does E.O. 13622 make sanctionable activities related to the pipeline project to supply natural gas from the Shah Deniz gas field in Azerbaijan to Europe and Turkey, given that NICO reportedly has a 10 percent stake in the project? |
| 223 |
Are barter arrangements or other non-cash trade transactions involving petroleum, petroleum products, or petrochemical products originating from Iran sanctionable under the terms of the new E.O. 13622? |
| 224 |
What are the definitions of “petroleum products” and “petrochemical products”? |
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| Questions Related to Humanitarian Assistance to Syria |
The United States government is working with the international community to provide urgently needed humanitarian assistance to the Syrian people while applying comprehensive sanctions against the Government of Syria and targeted sanctions on key individuals and entities supporting the Assad regime, in order to continue pressuring the Syrian government to stop its human rights abuses and other illicit activities. The following frequently asked questions provide an overview of the U.S. Department of the Treasury’s Syria sanctions program and guidance to the public on sending remittances, goods and services, and charitable assistance to Syria.
For additional Treasury guidance on protecting charitable donations from abuse, please view this document or visit this website: www.treasury.gov/resource-center/terrorist-illicit-finance/Documents/Treasury%20Charity%20FAQs%206-4-2010%20FINAL.pdf. Additional questions may be directed to Treasury’s Office of Foreign Assets Control (OFAC) hotline at (800) 540-6322 or (202) 622-2490. |
| 225 |
Why does the United States have sanctions against Syria and what does that mean for me? |
| 226 |
How can I help the Syrian people while making sure to abide by the U.S. sanctions? |
| 227 |
May I continue to send money to family or friends in Syria? |
| 228 |
May I send personal remittances through the Commercial Bank of Syria, the Syrian-Lebanese Commercial Bank, or the Syria International Islamic Bank (SIIB) to family or friends in Syria? |
| 229 |
Do I need a specific license from OFAC to send U.S.-origin food or medicine to Syria? |
| 230 |
Can I give donations to NGOs to help the Syrian people? |
| 231 |
Can U.S. NGOs deliver humanitarian assistance directly to Syria? |
| 232 |
As an individual, can I send financial donations directly to Syria in support of charitable activities under General License No. 11? |
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