Are barter trades involving the Central Bank of Iran (CBI) considered “financial transactions” under Section 1245?

OFAC's answer

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

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• #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”?