How does OFAC define an Iranian account, and why it should matter to you!


ITSR allows U.S. depository institutions to process transfers of funds to or from Iran when the underlying transaction is permitted by the current general licenses stated in ITSR or if there is a specific license issued by OFAC. It also must not involve the debiting or crediting of an Iranian account. A U.S. depository institution refers to any entity organized under the laws of the United States or any jurisdiction within the United States or any agency, office, or branch in the United States of a foreign entity primarily engaged in banking.

Iranian Account:

An Iranian Account is maintained on the books of a U.S. depository institution by a person who is a resident of Iran (someone who spends six months or more in Iran). However, this only applies to an individual who is physically living in Iran. It includes persons blocked by § 560.211, such as the Government of Iran or an Iranian financial institution.

Since the United States and Iran do not have any banking relationships, there is no way to directly send money from a U.S. bank to an Iranian bank and vice versa. The only way one can transfer funds is through the use of a currency exchange broker.

Therefore, when receiving funds from Iran and or sending funds to Iran, an individual should ensure they are doing so with a currency exchange broker that effectuates these transactions through a third-country bank and that it does not involve an Iranian account (an account of an Iranian resident held at a United States bank).

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