§560.405 Transactions ordinarily incident to a licensed transaction authorized.
Any transaction ordinarily incident to a licensed transaction and necessary to give effect thereto is also authorized, except:
(a) An ordinarily incident transaction, not explicitly authorized within the terms of the license, involving a debit to a blocked account or a transfer of blocked property;
(b) Payments or transfers of funds;
Note to paragraph (b) of §560.405: See §560.516 for a general license authorizing United States depository institutions or United States registered brokers or dealers in securities to process transfers of funds if the transfer arises from, and is ordinarily incident and necessary to give effect to, an underlying transaction authorized by a specific or general license issued pursuant to, or set forth in, this part.
(c) Provision of any transportation services to or from Iran not explicitly authorized in or pursuant to this part other than loading, transporting,...
1) Except as otherwise discussed, this provision is substantively identical across sanctions programs. OFAC appears to interpret, in a harmonious manner cross-programmatically, the construction “[a]ny transaction ordinarily incident to a licensed transaction and necessary to give effect thereto is also authorized,” at least as it appears in the 400-level interpretive provision. Differences in the scope of the 400-level ordinarily incident provision across programs are made explicit, through carveouts such as those found in 560.405.
Detailed discussions on the scope and operation of this provision—as well as the way in which the “ordinarily incident” issue is handled in the context of exempt transactions—can be found in the following documents: Notes Common to the 400-Level Interpretive Provisions Authorizing Transactions "Ordinarily Incident" to a Licensed Transaction; Transactions Incident to Others in General (System Ed. Note); General Note and Associated Matrix Pertaining to U.S. Person Engagement in Transactions...