OFAC’s IFCA/E.O. 13645 FAQ: Sectors Controlled by IRGC
The question (No 300): For purposes of sanctions under section 1245, how will I know which sectors are controlled by Iran’s Islamic Revolutionary Guard Corps? The answer: By July 1, 2013, a report will...
View ArticleOFCA’s IFCA/E.O. 13645 FAQ: Determining Section 1245 Applicability
The question (No 301): How will the determination be made as to whether materials are used in a manner that would make them subject to sanctions under section 1245 of IFCA? The answer: A FFI, prior to...
View ArticleOFAC’s IFCA/E.O. 13645 FAQ: Section 1245 Exceptions
The question (No 302): Are there any exceptions to section 1245 of IFCA? The answer: A person will not be subject to sanctions under section 1245 of IFCA if a determination is made by the Department of...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: Insurance, Reinsurance and Underwriting
The question (No 303): Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under section 1246(a)(1)? The answer: A number of insurance activities are subject...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: Facilitating Transactions with...
The question (No 305): Sanctions under section 1247 of IFCA apply to FFIs that facilitate financial transactions on behalf of an Iranian person on the SDN List. How does the Executive Order relate to...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: E.O. 13645 questions
The question (No 306): How does the Executive Order relate to the IFCA provisions? The answer: The E.O. provides additional tools related to the IFCA provisions by: a. Authorizing prohibitions or...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: Material Assistance Sanctions
The question (No 308): What are the implications of the material assistance provision of the Executive Order? The answer: Subsection 2(a)(i) of the E.O. authorizes the Department of the Treasury to...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: Iranian Rial Transactions
The question (No 309): What transactions involving the Iranian rial will be subject to sanctions? The answer: FFIs risk correspondent and payable-through account and blocking sanctions for (i)...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: Iranian Automotive Sector
The question (No 310): What is considered Iran’s automotive sector for purposes of the Executive Order? The answer: The E.O. authorizes the imposition of correspondent and payable-through account and...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: Financial Transactions for “Certain...
The question (No 312): How does the Executive Order tighten the financial sanctions applicable to FFIs under section 1247 of IFCA? The answer: Section 3 of the E.O. tightens the financial sanctions...
View ArticleMay 29, 2014: OFAC Updates Iran, Iraq, WMD sanctions lists
On Tuesday, OFAC modified a number of sanctions programs. First, the following have been added to the SDN list under either the IFSR (Iran Financial Sanctions Regulations), Executive Order 13645 (part...
View ArticleOFCA’s IFCA/E.O. 13645 FAQ: Determining Section 1245 Applicability
The question (No 301): How will the determination be made as to whether materials are used in a manner that would make them subject to sanctions under section 1245 of IFCA? The answer: A FFI, prior to...
View ArticleOFAC’s IFCA/E.O. 13645 FAQ: Section 1245 Exceptions
The question (No 302): Are there any exceptions to section 1245 of IFCA? The answer: A person will not be subject to sanctions under section 1245 of IFCA if a determination is made by the Department of...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: Insurance, Reinsurance and Underwriting
The question (No 303): Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under section 1246(a)(1)? The answer: A number of insurance activities are subject...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: Facilitating Transactions with...
The question (No 305): Sanctions under section 1247 of IFCA apply to FFIs that facilitate financial transactions on behalf of an Iranian person on the SDN List. How does the Executive Order relate to...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: E.O. 13645 questions
The question (No 306): How does the Executive Order relate to the IFCA provisions? The answer: The E.O. provides additional tools related to the IFCA provisions by: a. Authorizing prohibitions or...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: Material Assistance Sanctions
The question (No 308): What are the implications of the material assistance provision of the Executive Order? The answer: Subsection 2(a)(i) of the E.O. authorizes the Department of the Treasury to...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: Iranian Rial Transactions
The question (No 309): What transactions involving the Iranian rial will be subject to sanctions? The answer: FFIs risk correspondent and payable-through account and blocking sanctions for (i)...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: Iranian Automotive Sector
The question (No 310): What is considered Iran’s automotive sector for purposes of the Executive Order? The answer: The E.O. authorizes the imposition of correspondent and payable-through account and...
View ArticleOFAC’s IFCA/Executive Order 13645 FAQ: Financial Transactions for “Certain...
The question (No 312): How does the Executive Order tighten the financial sanctions applicable to FFIs under section 1247 of IFCA? The answer: Section 3 of the E.O. tightens the financial sanctions...
View Article