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Frequently Asked Questions

833. How will the terms “knowingly” and “significant” be interpreted for purposes of Executive Order (E.O.) 13902?


As a general matter, the Department of the Treasury intends to rely, where applicable, on definitions of terms previously included in Treasury regulations.

For purposes of E.O. 13902, OFAC will rely on the definition of "knowingly" included in the Iranian Financial Sanctions Regulations at 31 C.F.R. § 561.314 ("The term knowingly, with respect to conduct, a circumstance, or a result, means that a person has actual knowledge, or should have known, of the conduct, the circumstance, or the result.").

In determining whether goods or services used in connection with a sector of the Iranian economy identified pursuant to E.O. 13902 are “significant,” the Department of the Treasury may consider the totality of the facts and circumstances. As a general matter, the Department of the Treasury may consider some or all of the following broad factors: (a) the value and number of goods or value and frequency of services; (b) the nature of the good or services, including their type, complexity, and commercial purpose; (c) the level of awareness of management and whether the provision of goods or services is part of a pattern of conduct; (d) the involvement of designated persons in transactions involving goods and services defined in FAQ 832; (e) the impact of the provision of goods or services on the objectives of E.O. 13902; (f) whether the provision of the goods or services involved deceptive practices; and (g) other relevant factors that the Secretary of the Treasury deems relevant.

Date Released
June 5, 2020