OFAC FAQ #619 · Iran Sanctions
Are barter arrangements or other non-cash trade transactions involving petroleum, petroleum products, or petrochemical products originating from Iran sanctionable under the terms of E.O. 13846?
OFAC's answer
Yes. To the extent a financial institution is involved, that financial institution could be sanctioned under [E.O. 13846](https://ofac.treasury.gov/media/30181/download?inline) for a barter arrangement, on or after November 5, 2018, related to the purchase or acquisition of petroleum, petroleum products, or petrochemical products from Iran. In addition, barter transactions knowingly conducted with NIOC, NICO, or the CBI also could result in sanctions — regardless of whether a financial institution is involved — to the extent that those transactions constitute material support for, or services to, NIOC, NICO, or the CBI.