OFAC FAQ #261 · Iran Sanctions
Are there any circumstances in which funds can be transferred to third-country financial institutions?
OFAC's answer
Transfers on or after February 6, 2013, of funds deposited in the RECIPIENT ACCOUNT or the [SPECIAL PURPOSE ACCOUNT](https://ofac.treasury.gov/faqs/260) to third-country financial institutions are not covered by the National Defense Authorization Act's ([NDAA](https://ofac.treasury.gov/media/5761/download?inline)) [significant reduction exception](https://ofac.treasury.gov/faqs/254), and create exposure to sanctions for [FFI](https://www.ecfr.gov/cgi-bin/text-idx?SID=f001609e54e2c4adcbab5dafe63ba4a7&mc=true&node=se31.3.561_1308&rgn=div8)s conducting or facilitating such transfers, unless the transfer is to pay a third-country exporter for sales made pursuant to the Humanitarian Exception (see [FAQ 265](https://ofac.treasury.gov/faqs/265)).