OFAC FAQ #290 · Iran Sanctions
Are payments or deliveries that are made on or after July 1, 2013, for contracts that existed prior to July 1, 2013, exempted from IFCA provisions?
OFAC's answer
There is no general exception for payments, sales, deliveries, or transfers arising out of contracts entered into prior to July 1, 2013, on or after which date certain activities become sanctionable under the [Iran Freedom and Counter-Proliferation Act of 2012 (IFCA).](https://ofac.treasury.gov/media/30671/download?inline) The assessment of whether such payments are “significant” or result in the transfer of “significant goods or services” or “significant financial support” will be done on a case-by-case basis in line with the criteria discussed above.