1152. Could foreign financial institutions (FFIs) that engage in transactions in non-USD currencies be sanctioned under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?

Yes.  The prohibitions and targeting authorities of amended section 11 of E.O. 14024 apply with respect to any currency.  For example, an FFI that processes any significant transaction(s) denominated in a non-USD local currency on behalf of a customer that exports critical items to Russia's military-industrial base risks being sanctioned by OFAC.  For further information on sanctions risk for FFIs under section 11 of E.O. 14024, see OFAC’s Advisory to Foreign Banks on Russia Sanctions Risks, FAQ 1148, and FAQ 1149.