Will the U.S. refrain from sanctioning foreign financial institutions that receive funds from the Central Bank of Iran (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 National Defense Authorization Act (NDAA)?

OFAC's answer

As [noted](https://ofac.treasury.gov/faqs/180), no general exception will be provided for payments arising out of pre-existing contracts. The assessment of whether such payments are “significant” will be done on a case-by-case basis in line with the criteria discussed in [FAQ #174](https://ofac.treasury.gov/faqs/174). Regarding payments for food, medicine, and medical devices, the [NDAA](https://ofac.treasury.gov/media/5761/download?inline) does not allow sanctions based on transactions for the sale of food, medicine, or medical devices to Iran. Payments related to the export of broader humanitarian items would be dealt with in our analysis of what constitutes a “significant financial transaction” and would be considered on a case-by-case basis.

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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”?
• #180Are payments made under contracts existing prior to the date of enactment of the National Defense Authorization Act (NDAA) statute (December 31, 2011) exempted from the definition of “significant transactions”?