If oil is being provided as payment for an outstanding debt, is such a transfer considered a “financial transaction”?

OFAC's answer

If a transfer involves a financial institution it would likely be considered a [financial transaction](https://ofac.treasury.gov/faqs/174).

Related programs

Related FAQs

• #174What 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”?