What are significant goods or services used in connection with a sector of the Iranian economy specified in Executive Order (E.O.) 13902?
OFAC's answer
Persons who have knowingly engaged in a significant transaction for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with the construction, mining, manufacturing, textiles, and financial sectors of the Iranian economy as described in [FAQ 831](https://ofac.treasury.gov/faqs/831) risk exposure to blocking sanctions pursuant to [E.O. 13902](https://ofac.treasury.gov/media/31406/download?inline). Further, foreign financial institutions that have knowingly conducted or facilitated any significant financial transaction for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with those sectors of the Iranian economy risk exposure to U.S. correspondent account or payable-through account sanctions. OFAC expects to promulgate regulations defining goods and services used in connection with the construction, mining, manufacturing, textiles, and financial sectors of the Iranian economy consistent with the following (See [FAQ 833](https://ofac.treasury.gov/faqs/833) for an interpretation of the term "significant."): Goods or services used in connection with the construction sector of the Iranian economy: The term goods used in connection with the construction sector of the Iranian economy means equipment or materials that enable the services described below or the activities described in [FAQ 831](https://ofac.treasury.gov/faqs/831) with respect to the construction sector of the Iranian economy, including: building supplies, concrete, scaffolding, lifts, hoists, cranes, conveyors, and mechanized equipment for material handling. Goods that ensure the protection of life and prevention of injuries to persons operating in the construction sector of the Iranian economy are excluded from this definition, including personal protective equipment, safety devices, and alarm systems. The term services used in connection with the construction sector of the Iranian economy include: blasting, demolition, dredging, electrical work, excavating, masonry, plumbing, rigging, welding, for-sale building, design-build consultations, and construction management. Services that ensure the protection of life and prevention of injuries to persons operating in the construction sector of the Iranian economy are excluded from this definition, including cleaning, safety inspections, and services necessary for use of protective goods described above. Goods or services used in connection with the mining sector of the Iranian economy: The term goods used in connection with the mining sector of the Iranian economy means equipment or materials that enable the services described below or the activities described in [FAQ 831](https://ofac.treasury.gov/faqs/831) with respect to the mining sector of the Iranian economy, including: boring equipment, conveyor belts, directional digging technology, haul trucks, hydraulic excavators, explosives, and power shovels. Goods that ensure the protection of life and prevention of injuries to persons operating in mines in Iran are excluded from this definition, including personal protective equipment, safety devices, ventilation systems, and alarm systems. The term services used in connection with the mining sector of the Iranian economy includes: auguring, boring, backfilling, combusting, crushing, exploration, grinding, grading, irrigating, impounding, magnetic separation, mineral processing, geophysical surveying, mapping services, operating mines or quarries, site preparation, and related construction activities. Services that ensure the protection of life and prevention of injuries to persons operating in the mining sector of the Iranian economy are excluded from this definition, including rescue and accident response services, cleaning, safety inspections, and services necessary for use of protective goods described above. Goods or services used in connection with the manufacturing sector of the Iranian economy: The term goods used in connection with the manufacturing sector of the Iranian economy means equipment or materials, including raw materials, tooling machinery, and components of finished products, that enable the services described below. Goods that ensure the protection of life and prevention of injuries to persons operating in the manufacturing sector of the Iranian economy are excluded from this definition, including personal protective equipment, safety devices, and alarm systems. The term services used in connection with the manufacturing sector of the Iranian economy includes: new installment, additions, alteration, maintenance, and repair of manufacturing equipment; procurement or supply of raw materials for the manufacturing sector of the Iranian economy; and distribution services to persons operating in the manufacturing sector of the Iranian economy. Services that ensure the protection of life and prevention of injuries to persons operating in the manufacturing sector of the Iranian economy are excluded from this definition, including cleaning services, safety inspections, and services necessary for use of protective goods described above. Goods or services used in connection with the textiles sector of the Iranian economy: The term goods used in connection with the textiles sector of the Iranian economy means equipment, machines, materials, and items used in the textiles sector of the Iranian economy or that enable the services described below or the activities described in [FAQ 831](https://ofac.treasury.gov/faqs/831) with respect to the textiles sector of the Iranian economy, including: looms, industrial sewing machines, industrial washers and dryers, and industrial embroidery machinery. Goods that ensure the protection of life and prevention of injuries to persons operating in the textiles sector of the Iranian economy are excluded from this definition, including personal protective equipment, safety devices, and alarm systems. The term services used in connection with the textiles sector of the Iranian economy includes: procurement or supply of raw materials for textiles production, and design of textiles products. Services that ensure the protection of life and prevention of injuries to persons operating in the textiles sector of the Iranian economy are excluded from this definition, including cleaning services, safety inspections, and services necessary for use of protective goods described above. Goods or services used in connection with the financial sector of the Iranian economy: On or after November 22, 2020, persons who have knowingly engaged in a significant transaction for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with the financial sector of the Iranian economy risk exposure to blocking or other sanctions under [E.O. 13902](https://ofac.treasury.gov/media/31406/download?inline), unless the transaction is for a permitted transaction, such as humanitarian trade or a transaction or activity authorized for U.S. persons or otherwise described in FAQs [844](https://ofac.treasury.gov/faqs/844), [847](https://ofac.treasury.gov/faqs/847), [855](https://ofac.treasury.gov/faqs/855), or [856](https://ofac.treasury.gov/faqs/856). The term goods or services used in connection with the financial sector of the Iranian economy includes new hardware or software, or upgrades to existing hardware or software, and related services, for use by Iranian financial institutions sanctioned pursuant to E.O. 13902 or the Iranian financial sector. It also includes financial services for transactions other than permitted transactions (e.g., humanitarian trade or transactions or activities authorized for U.S. persons or otherwise described in FAQs [844](https://ofac.treasury.gov/faqs/844), [847](https://ofac.treasury.gov/faqs/847), [855](https://ofac.treasury.gov/faqs/855), or [856](https://ofac.treasury.gov/faqs/856). The term does not include goods or services ordinarily incident and necessary to: - The wind down of accounts, transactions, operations, contracts, or other agreements involving the Iranian financial sector or an Iranian financial institution sanctioned pursuant to E.O. 13902 that were in effect prior to October 8, 2020. - The maintenance of accounts, transactions, operations, contracts, and other agreements involving the Iranian financial sector or an Iranian financial institution sanctioned pursuant to E.O. 13902 that were in effect prior to October 8, 2020 and: (i) are used in connection with permitted transactions, such as humanitarian trade or transactions or activities authorized for U.S. persons or otherwise described in FAQs [844](https://ofac.treasury.gov/faqs/844), [847](https://ofac.treasury.gov/faqs/847), [855](https://ofac.treasury.gov/faqs/855), or [856](https://ofac.treasury.gov/faqs/856) or (ii) are otherwise necessary for the continued processing of such permitted transactions. The Department of the Treasury continues to analyze goods and services used in connection with the financial sector of the Iranian economy and may issue additional guidance about the types of goods and services that are considered sanctionable for purposes of E.O. 13902. We urge caution in any dealings involving the Iranian financial sector or with an Iranian financial institution sanctioned pursuant to E.O. 13902.
Related programs
Related FAQs
- #831How will OFAC define the sectors of the Iranian economy specified in Executive Order (E.O.) 13902 of January 10, 2020?
- #833How will the terms “knowingly” and “significant” be interpreted for purposes of Executive Order (E.O.) 13902?
- #844Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions, or other activities that would be authorized under the Iranian Transactions and Sanctions Regulations and General License (GL) L if engaged in by a U.S. person, involving Iranian financial institutions (Iranian FIs) sanctioned pursuant to E.O. 13902?
- #847As a result of the sanctions on the Iranian financial sector and certain Iranian financial institutions (Iranian FIs) pursuant to Executive Order (E.O.) 13902, do non-U.S. persons risk exposure to sanctions for continuing to engage in previously non-sanctionable trade involving the Iranian financial sector or E.O. 13902-sanctioned Iranian FIs, even after the end of the 45-day wind-down period?
- #855How will transactions related to official activities of international organizations be treated for purposes of secondary sanctions to the extent that the Iranian financial sector or Iranian financial institutions sanctioned under Executive Order (E.O.) 13902 are involved?
- #856How will transactions related to Iran’s participation in legal proceedings, including administrative, judicial, arbitral proceedings, and proceedings before international courts and tribunals, be treated for purposes of secondary sanctions to the extent that Iranian financial institutions or the Iranian financial sector sanctioned under Executive Order (E.O.) 13902 are involved?