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Frequently Asked Questions - Newly Added

No, provided that the provision of services is not an indirect export to a person located in the Russian Federation.  For the purposes of the IT and Software Services Determination, OFAC interprets the “indirect” provision of the prohibited services to include when the benefit of the services is ultimately received by a “person located in the Russian Federation.”

In contrast, OFAC would not consider to be prohibited the provision of services to a third country company that is located outside of Russia, including such a company owned or controlled by persons located in the Russian Federation, provided that the services will not be further exported or reexported to persons located in the Russian Federation.

For example, the following scenarios describe services that would be prohibited under the IT and Software Services Determination:

  • A U.S. company designs and delivers proprietary supply chain management software to a third country limited liability company (Company X) on behalf of its Russian parent company, which Company X intends to supply to its parent company.
  • A U.S. company designs and delivers proprietary accounting software to a third country software re-seller (Company Y), which Company Y indicates that they intend to supply to a Russian company. 
  • A U.S. consulting company signs a contract to provide enterprise management software and related information technology support services to Company X.  Company X provides access to these services to its Russian parent, such that employees from the Russian parent call the U.S. consulting company when they have problems with their enterprise management software. 

The following scenarios illustrate services to a non-Russian subsidiary of a Russian person that would not be prohibited under the IT and Software Services Determination:

  • A U.S. software company assists a U.S. subsidiary of a Russian company in upgrading the U.S. subsidiary’s IT systems, including procuring new software and hardware.  The U.S. subsidiary has an office and employees in the United States and conducts business in the United States, and the services will not be exported or reexported to the Russian parent company.
  • A U.S. software company signs a contract with the third-country subsidiary (Company Z) of a Russian company for the delivery via cloud of building information software to Company Z.  This subsidiary has an office and employees in the third country and conducts business in this third country, and the software will not be provided to the Russian parent company.
  • A U.S. technology company designs a website for the subsidiary of a Russian company located in a third country. This subsidiary has an office and employees in the third country and conducts business in this third country, and the services will not be reexported to the Russian parent company.
     
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OFAC expects to promulgate regulations that define or interpret these terms as follows:

The term enterprise management software means the following types of software:  enterprise resource planning (ERP), customer relationship management (CRM), business intelligence (BI), supply chain management (SCM), enterprise data warehouse (EDW), computerized maintenance management system (CMMS), project management, and product lifecycle management (PLM) software.

The term design and manufacturing software means the following types of software:  building information modelling (BIM), computer aided design (CAD), computer-aided manufacturing (CAM), and engineer to order (ETO) software.

The term cloud-based services includes the delivery of software via the internet or over the cloud, including through Software-as-a-Service (SaaS), or SaaS cloud services in relation to such software. 

The term information technology support services is defined consistent with the United Nations’ Central Product Classification (CPC) Code 83132 to include:  

  1. providing technical expertise to solve problems for the client in using software, hardware, or an entire computer system, such as: (a) providing customer support in using or troubleshooting the software; (b) upgrading services and the provision of patches and updates; (c) providing customer support in using or troubleshooting the computer hardware, including testing and cleaning on a routine basis and repair of information technology (IT) equipment; (d) technical assistance in moving a client’s computer system to a new location; (e) providing customer support in using or troubleshooting the computer hardware and software in combination; and
  2. providing technical expertise to solve specialized problems for the client in using a computer system, such as:  (a) auditing or assessing computer operations without providing advice or other follow-up action including auditing, assessing and documenting a server, network or process for components, capabilities, performance, or security; (b) data recovery services, i.e. retrieving a client’s data from a damaged or unstable hard drive or other storage medium, or providing standby computer equipment and duplicate software in a separate location to enable a client to relocate regular staff to resume and maintain routine computerized operations in event of a disaster such as a fire or flood; and (c) other IT technical support services not elsewhere classified.

The term information technology consultancy and design services includes both IT consulting services and IT design and development services for applications, and is defined consistent with United Nations’ Central Product Classification (CPC) Codes 83131 and 83141, respectively.

  • IT consultancy services includes providing advice or expert opinion on technical matters related to the use of information technology, such as:  (a) advice on matters such as hardware and software requirements and procurement; (b) systems integration; (c) systems security; and (d) provision of expert testimony on IT related issues. 
  • IT design and development services for applications includes services of designing the structure and/or writing the computer code necessary to create and/or implement a software application, such as:  (a) designing the structure of a web page and/or writing the computer code necessary to create and implement a web page; (b) designing the structure and content of a database and/or writing the computer code necessary to create and implement a database; (c) designing the structure and writing the computer code necessary to design and develop a custom software application; (d) customization and integration, adapting (modifying, configuring, etc.) and installing an existing application so that it is functional within the clients’ information system environment.
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The IT and Software Services Determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of both IT support services and cloud-based services for the Covered Software to a person located in the Russian Federation.  IT support services include the provision of technical expertise to solve problems for the client in using software, hardware, or an entire computer system.  Cloud-based services include the supply of software and associated services via the internet or the cloud, including through Software-as-a-Service (SaaS).  See FAQ 1187 for more information on how OFAC intends to define “enterprise management software,” “design and manufacturing software,” “cloud-based services,” and “information technology support services.”

The following are examples of activities that would be prohibited by the IT and Software Services Determination if such services were provided to a company located in the Russian Federation that is not owned or controlled directly or indirectly by a U.S. person (Russian company):

  • A U.S. company sells a cloud-based enterprise resource planning software subscription to a Russian company.
  • A U.S. employee of a third country company provides customer support services to a Russian company that is experiencing technical difficulties with its human resources software.
  • A U.S. company provides a software patch to a Russian company to fix a bug in its computer-aided design software.

The following are examples of activities that would not be prohibited by the IT and Software Services Determination:

  • A U.S. company sells a cloud-based electronic health records software subscription to a Russian company.  
  • A U.S. company provides customer support services to a Russian individual who is experiencing technical difficulties with their publicly available cloud-based spreadsheet web application. 
  • A U.S. person working at a third country company provides customer support services to a Russian individual who is experiencing technical difficulties with their free-of-charge publicly available teleconferencing application.
  • A U.S. company provides IT support services to a Russian individual to a non-covered software application.

The IT and Software Services Determination complements regulations to be issued by the U.S. Department of Commerce Bureau of Industry and Security (BIS) pertaining to the export, reexport, or transfer (in-country) to the Russian Federation of the following types of software subject to the Export Administration Regulations, 15 CFR part 730–774 (EAR):  Enterprise resource planning (ERP); customer relationship management (CRM); business intelligence (BI); supply chain management (SCM); enterprise data warehouse (EDW); computerized maintenance management system (CMMS); project management software, product lifecycle management (PLM);  building information modelling (BIM); computer aided design (CAD); computer-aided manufacturing (CAM); and engineering to order (ETO).

See General License (GL) 25D for more information about certain authorizations for transactions relating to the receipt or transmission of telecommunications involving the Russian Federation and the provision of certain services incident to the exchange of communications over the internet.  See GL 6D for more information on authorizations for transactions related to certain agricultural and medical activities involving the provision of information technology and software-related services. 

As noted in FAQ 1185, some of these activities may be subject to other Federal laws or requirements of other Federal agencies, including export, reexport, and transfer (in-country) licensing requirements maintained by the BIS under the EAR.
 

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IT consultancy and design services include the development and implementation of software, as well as assistance or advice relating to the development and implementation of software, including the supply and installation of bespoke software.  However, the retail sale of off-the-shelf software, falling under United Nations’ Central Product Classification (CPC) Code 63252, is not included in the scope of IT consultancy and design services.  IT consultancy and design services are distinct from information technology (IT) support services, which fall under United Nations’ CPC Code 83132.  See FAQ 1187 for more information on how OFAC intends to define “IT consultancy and design services.”  See FAQ 1186 for a description of prohibited “IT support services” and “cloud-based services” for enterprise management software and design and manufacturing software. 

The following are examples of activities that would be prohibited by the IT and Software Services Determination if such services were provided to a company located in the Russian Federation that is not owned or controlled directly or indirectly by a U.S. person (Russian company):

  • A U.S. company signs a contract with a Russian company to assist the Russian company in upgrading its IT systems.  The U.S. consulting company advises on, among other matters, the kinds of software and hardware needed for the Russian company’s operations and how best to procure such technology. 
  • A U.S. company works to modify existing web applications to be functional within a Russian company’s internal IT environment.
  • A U.S. service provider signs a contract with a Russian company for the design and engineering of bespoke (i.e., custom-made) software that the Russian company uses for internal purposes.
  • A U.S. person working at a third country company signs a contract with a Russian company to design the structure of their sales website.

The following are examples of activities that would not be prohibited by the IT and Software Services Determination: 

  • A U.S. service provider provides a Russian company with internet access. 
  • A U.S. service provider provides a Russian company with internet services.  The delivery of internet services includes, for example, Domain Name Services.
  • A U.S. company provides Russian individuals and entities with continued access to cloud-based, free-of-charge, publicly available web applications, such as email, spreadsheet, and document applications.
  • A U.S. company provides virtual private network (VPN) services to customers in the Russian Federation.

Some of these activities – such as the sale of off-the-shelf software – may be subject to other Federal laws or requirements of other Federal agencies, including export, reexport, and transfer (in-country) license requirements maintained by the Department of Commerce’s Bureau of Industry and Security under the Export Administration Regulations, 15 CFR parts 730–774 (EAR).   
 

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In line with G7 efforts to disrupt Russia’s defense industry’s reliance on western IT systems, on June 12, 2024, Treasury issued a determination that restricts the provision of certain IT and software-related services to Russia.  The determination, “Prohibition on Certain Information Technology and Software Services,” issued pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”), prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, to any person located in the Russian Federation of:  (1) IT consultancy and design services; and (2) IT support services and cloud-based services for the following categories of software: enterprise management software and design and manufacturing software (collectively, “Covered Software”).  The IT and Software Services Determination will take effect at 12:01 a.m. eastern daylight time on September 12, 2024.  See FAQs 1185, 1186, 1187, and 1188 for additional information. 

The aim of this action is not to prohibit all activity relating to the provision of IT and software-related services to Russia.  The United States strongly supports the free flow of information and communications globally as facilitated by telecommunications and the internet.  These measures do not prohibit internet access or the delivery of internet-based communications services.  Treasury already has in place General License (GL) 25D, which authorizes certain transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation and the provision of certain services incident to the exchange of communications over the internet, subject to certain restrictions.  For additional information, see FAQ 1040.  Treasury has also amended GL 6D to authorize transactions related to certain agricultural and medical activities involving the provision of information technology and software-related services.  Additionally, the importation from any country, or the exportation to any country of any information or informational materials, regardless of format or medium, is generally exempt from the scope of sanctions prohibitions under the International Emergency Economic Powers Act.  See 50. U.S.C. § 1702(b)(3).

In addition, the IT and Software Services Determination does not prohibit the following IT and software services, which are excluded from its scope:  (1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a United States person; (2) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person; and (3) any service for software that would be eligible for a license exception or otherwise authorized for export or reexport to Russia by the Department of Commerce.
 

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On June 12, 2024, OFAC issued Russia-related general licenses (GLs) GL 99, GL 100, and amended GL 8J, authorizing certain transactions involving MOEX, NCC, NSD, or any entity in which one of these entities owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively, “the Blocked Entities”).

GL 99 authorizes the wind down of transactions involving the Blocked Entities, as well as certain transactions related to the divestment to non-U.S. persons of debt or equity issued or guaranteed by, or derivative contracts involving, the Blocked Entities.  For example, GL 99 would authorize a U.S. person to divest their equity in MOEX to a non-blocked non-U.S. person.  This authorization expires at 12:01 a.m. eastern daylight time August 12, 2024.  See GL 99 for more information. 

GL 100 authorizes certain transactions for the divestment to non-blocked, non-U.S. persons of debt or equity, or for the conversion of currencies, involving one or more of the Blocked Entities solely as a securities, trade, or settlement depository, central counterparty or clearing house, or public trading market.  GL 100 is intended to cover the divestment of debt or equity of non-blocked companies that may be traded on or through one of the Blocked Entities in their capacity as a securities, trade, or settlement depository, central counterparty or clearing house, or public trading market.  For example, GL 100 would authorize a U.S. person to divest their equity in a non-blocked Russian company that is being traded on MOEX to a non-blocked, non-U.S. person.  This example would be distinct from the divestment of equity in MOEX itself, which would be covered by GL 99.  GL 100 would also authorize U.S. persons to transact with one of the Blocked Entities to the extent ordinarily incident and necessary to convert U.S. dollars to another currency, or vice versa.  This authorization expires at 12:01 a.m. eastern daylight time August 12, 2024. See GL 100 for more information.

GL 8J authorizes certain transactions related to energy involving NCC.  See FAQ 976 for more information.

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Treasury remains focused on counteracting activity that involves sanctions evasion or third-country support to Russia’s military-industrial base. At the same time, legitimate humanitarian activity and agricultural and medical trade are not the target of our sanctions. Accordingly, FFIs may continue to conduct or facilitate any transaction(s) or provide any service related to activities that are otherwise authorized or exempted under the Russian Harmful Foreign Activities Sanctions program. Foreign persons do not risk the imposition of sanctions for engaging in transactions authorized for U.S. persons under General Licenses issued under the Russian Harmful Foreign Activities Sanctions program. 

FFIs may continue to rely on Treasury’s existing authorizations in place for transactions related to agricultural commodities, medicine, medical devices and related replacement parts, components, or software updates, the Coronavirus Disease 2019 (General License (GL) 6D), energy-related transactions (GL 8J), certain transactions in support of non-governmental organizations (GL 27), official business of third-country diplomatic or consular missions located in the Russian Federation (GL 20), certain transactions and official business of certain international organizations and entities by employees, grantees, or contractors thereof (31 CFR 587.510). Additionally, the importation or exportation of information or informational materials and transactions ordinarily incident to travel to or from any country are exempt under the International Emergency Economic Powers Act (IEEPA).  

See OFAC’s Advisory to Foreign Banks on Russia Sanctions Risks for additional guidance. 
 

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In line with G7 commitments and in response to the Government of the Russian Federation’s continued efforts to reorient its economy and government resources to support its war effort, Treasury has updated its definition of Russia’s military-industrial base to include all persons blocked pursuant to E.O. 14024.  This updated definition reflects Russia’s reorientation of its economy and government resources to support its war.  This action means that FFIs risk being sanctioned for conducting or facilitating any significant transaction or transactions or for providing any service involving a person blocked pursuant to E.O. 14024. 

As updated in FAQ 1151, Russia’s military-industrial base includes all persons blocked pursuant to E.O. 14024, as well as any person operating in the technology, defense and related materiel, construction, aerospace, and manufacturing sectors of the Russian Federation economy (and other sectors as may be determined pursuant to E.O. 14024).  For definitions of those identified sectors, see FAQ 1126.  Russia’s military-industrial base may also include individuals and entities that support the sale, supply, or transfer, directly or indirectly, of critical items identified pursuant to subsection 11(a)(ii) of E.O. 14024 to the Russian Federation.  See determination of December 22, 2023 pursuant to subsection 11(a)(ii) of Executive Order 14024 (Russia Critical Items Determination). 

OFAC has also updated its Advisory to Foreign Banks on Russia Sanctions Risks to provide additional guidance for FFIs.  For additional information, see FAQs 1147, 1148, 1149, 1150, 1151, 1152, and 1182.
 

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On June 5, 2024, OFAC, in consultation with the Department of State, amended the SySR to, among other things, incorporate certain sanctions statutes, including the Caesar Syria Civilian Protection Act of 2019, which are designed to deny the Assad Regime the resources it needs to support its longstanding campaign of repression against the Syrian people.  The amendments also incorporate a web General License (GL) and modify certain existing GLs to facilitate the continued provision of legitimate humanitarian assistance and internet-based communications services to civilians in Syria and clarify the applicability of the SySR to persons sanctioned under certain sanctions authorities.  These changes include:

  • Incorporation of Executive order and sanctions statutes 

OFAC incorporated into the SySR the Caesar Syria Civilian Protection Act of 2019, the Syria Human Rights Accountability Act of 2012, and the Iran Threat Reduction and Syria Human Rights Act of 2012, as well as relevant provisions of the Countering America’s Adversaries Through Sanctions Act and Executive Order (E.O.) 13608.

  • Incorporation of web GL 22 related to economic sectors in certain areas of Syria

OFAC incorporated into the SySR, at new § 542.533, web GL 22, which authorizes activities in certain economic sectors in non-regime held areas of Northeast and Northwest Syria. 

  • Additional non-governmental organization (NGO) activities

OFAC amended the GL related to the activities of nongovernmental organizations (NGO) at § 542.516.  These changes clarify which types of persons are covered by the NGO GL; add new authorized activities; and clarify that U.S. financial institutions may rely on statements of the originator of a funds, provided that the financial institution does not know or have reason to know that the funds transfer is not in compliance with the NGO GL.

  • Additional international organizations (IO)

OFAC amended the GL related to the activities of international organizations (IO) at § 542.513.  These changes add new IOs whose official business is authorized by the GL to include the International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies; and The Global Fund to Fight AIDS, Tuberculosis, and Malaria, and Gavi, the Vaccine Alliance. 

  • Expansion of authorization for internet-based communications

OFAC amended the GL related to internet-based communications at § 542.511.  These changes update the list of examples of communications technologies that are incident to, or enable services incident to, communications over the internet; authorize the provision of services incident to the export or reexport of certain communications software or hardware not subject to the Export Administration Regulations (“EAR”), 15 C.F.R. parts 730-774, that is incident to, or enables services incident to, communications over the internet, subject to certain conditions; and authorize the exportation and re-exportation to Syria of non-commercial-grade internet connectivity services

For more information, see FAQs 205, 206, 231, 232, 934, and 938.
 

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Section 515.340 defines the term “independent private sector entrepreneur” to mean a Cuban national who is not a prohibited official of the Government of Cuba or a prohibited member of the Cuban Communist Party, and who is one or more of the following:  (a) an owner, including a self-employed individual (cuentapropista), or employee of a small private business entity, private cooperative, or a sole proprietorship located in Cuba, in each case of up to 100 employees; (b) an independent contractor or consultant; (c) a small farmer who owns his or her own land; (d) a small usufruct farmer who cultivates state-owned land to sell products on the open market; or (e) a private cooperative or small private business entity located in Cuba of up to 100 employees that is owned only by individuals described in paragraphs (a) through (d) of § 515.340.  For example, small private business entities or private cooperatives owned only by independent private sector entrepreneurs, as defined, could include:

  • Agricultural businesses and farming cooperatives;
  • Animal feed and veterinary services;
  • IT services, software development businesses, and mobile application developers
  • Food and beverage importers, production/processing businesses, packaging and food distributors;
  • Clothing, jewelry, fashion design, and beauty/cosmetics suppliers and services;
  • Historic preservation and cultural preservation businesses;
  • Arts-related businesses; 
  • Machinery manufacturing and repair businesses;
  • Shipping, logistics, expediting, and delivery of goods businesses;
  • Medical supply businesses;
  • Restaurants and bars;
  • Taxis and transportation services;
  • Bed and breakfasts;
  • Manufacturing companies;
  • Business consulting services, marketing and branding services;
  • Accounting and bookkeeping services;
  • Home construction business and remodeling, plumbing, electrical, or other repair companies for business or residential facilities and homes;
  • Furniture design and manufacturing companies;
  • Travel services;
  • Vendors of personal care and household items, furniture, and appliances;
  • Interior decoration and design businesses;
  • Film and media production or journalism businesses;
  • Gyms, personal training, or fitness classes; and
  • Mechanical services (automobile, refrigeration, heating and A/C services and repair).
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Section 515.582 of the CACR authorizes persons subject to U.S. jurisdiction to import certain goods and services produced by independent private sector entrepreneurs, as determined by the State Department and set forth on the State Department's Section 515.582 List.  See FAQ 770.

In determining whether a good is produced by an independent private sector entrepreneur, as defined in 31 CFR § 515.340, persons subject to U.S. jurisdiction should consider the extent of Cuban state-owned entities’ involvement in the production and exportation of such goods.  For example, goods generally are not considered produced by independent private sector entrepreneurs if the manufacturing or processing conducted by Cuban state-owned entities results in a product with a new name, character, or use.  For example, an agricultural commodity grown by an independent grower but then processed by Cuban state-owned entities into a new product prior to exportation would not be a good produced by an independent private sector entrepreneur for purposes of 31 CFR § 515.582.  However, a good can still be considered produced by an independent private sector entrepreneur if, for example, Cuban state-owned entities are involved only in packing of the final product or acting solely as an export agent. 

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Section 515.578(a)(4)(i) of the CACR authorizes the exportation or reexportation, directly or indirectly, from the United States or by a person subject to U.S. jurisdiction, to a prohibited official of the Government of Cuba, as defined in 31 CFR § 515.337, a prohibited member of the Cuban Communist Party, as defined in 31 CFR § 515.338, of certain internet-based services and services related to certain exportations and reexportations, as described in 31 CFR § 515.578(a)(1) or 31 CFR § 515.578(a)(2), respectively, provided that such services are widely available to the public at no cost to the user.  Examples of authorized services include:

  • Social media platforms;
  • Collaboration platforms;
  • Video conferencing;
  • E-gaming and e-learning platforms;
  • Automated translation;
  • Web maps;
  • User authentication services;
  • Cloud-based services to support services described in section § 515.584(a)(1)(i); and
  • Services to install, repair, or replace items related to communication, or items used to develop software that improves the free flow of information or that will support private sector activities in Cuba consistent with the export or reexport licensing policy of the Department of Commerce.
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Section 515.578(b)(1) of the CACR excludes from authorization under 31 CFR 515.578(a)(1)-(3) the direct or indirect exportation or reexportation of services with knowledge or reason to know that such services are intended for a prohibited official of the Government of Cuba, as defined in 31 CFR § 515.337, a prohibited member of the Cuban Communist Party, as defined in 31 CFR § 515.338, or to organizations administered or controlled by the Government of Cuba or the Cuban Communist Party, except as specified in 31 CFR § 515.578(a)(4).

For purposes of assessing whether exports or reexports are excluded from 31 CFR § 515.578 pursuant to 31 CFR § 515.578(b)(1), internet-based service providers subject to U.S. jurisdiction may reasonably rely on information provided to them by their customers in the ordinary course of business, unless they know or have reason to know a transaction is not authorized.  

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Yes.  Section 515.578(a)(1)(i) of the CACR authorizes the direct or indirect exportation or reexportation to Cuba, from the United States or by a person subject to U.S. jurisdiction, of certain services. Among these are API-related services incident to the exchange of communications over the internet.  This authorization may include, for example, API services incident to, among other services described in 31 CFR § 515.578(a)(1)(i), web maps, social media platforms, collaboration platforms, video conferencing, and e-gaming and e-learning platforms.  Section 515.578(a)(ii) of the CACR authorizes the direct or indirect exportation or reexportation to Cuba, from the United States or by a person subject to U.S. jurisdiction, of services to support the exchange of communications over the internet, such as software design, business consulting, information technology management services, and cloud-based services (including remote data storage, data transport service, content distribution networks, virtual machines, software-as-a-service, and infrastructure-as-a-service).

With respect to the exportation or reexportation of API software to Cuba, including the download of such software, 31 CFR § 515.533(a) authorizes all transactions ordinarily incident to the export to Cuba of items from the United States, or reexport to Cuba of items from a third country, if the export or reexport is licensed or otherwise authorized by the Department of Commerce pursuant to the Export Administration Regulations (EAR) (15 CFR parts 730 through 774).  For example, the export and reexport to Cuba of certain software is authorized under License Exception Consumer Communications Devices (CCD), 15 CFR § 740.19, and License Exception Support for the Cuban People (SCP), 15 CFR § 740.21.

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Persons providing web hosting services authorized pursuant to 31 CFR § 515.578 may reasonably rely on information provided to them by their customers in the ordinary course of business, unless they know or have reason to know their provision of web hosting services is for the promotion of tourism.    

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User authentication services are services used to login or verify the identity of a user to a particular software or service, such as a user identification account often used to login to email, mobile app stores, or other activities authorized by 31 CFR § 560.540.

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No.  The processing, clearing, or sending of payments related to Russian metals by a U.S. bank on behalf of non-U.S. persons is not prohibited by the Metals Services Determination where the bank:  (1) is operating solely as an intermediary; and (2) does not have any direct relationship with the person providing a service covered by the Metals Services Determination (i.e., the person is a non-account party) as it relates to the relevant transaction.  Thus, the Metals Services Determination does not impose any new prohibitions or requirements relating to the processing, clearing, or sending of payments by intermediary banks.

Note that the above does not authorize U.S. banks to themselves provide any of the services prohibited by the Metals Services Determination indirectly or directly to a person located in the Russian Federation with respect to aluminum, copper, or nickel of Russian Federation origin.

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The Metals Services Determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of the following categories of services to any person located in the Russian Federation:  warranting services for aluminum, copper, or nickel of Russian Federation origin on a global metal exchange; and services to acquire aluminum, copper, or nickel of Russian Federation origin as part of the physical settlement of a derivative contract (collectively, “Covered Metals Acquisition Services”).  This determination does not apply to services related to aluminum, copper, or nickel of Russian Federation origin that was produced prior to April 13, 2024.

To ensure compliance with the Metals Services Determination, U.S. global metal exchanges should not accept aluminum, copper, or nickel of Russian Federation origin produced on or after April 13, 2024 (“covered Russian metals”).  U.S. global metal exchanges can further comply with the Metal Services Determination by halting the warranting of covered Russian metals on the exchange; removing brands that produce covered Russian metals from their list of accepted brands; abstaining from adding additional brands of covered Russian metals to their list of accepted brands; ceasing providing clearing services for covered Russian metals; and halting acting as a central counterparty to the trade of covered Russian metals. 

U.S. persons are also prohibited from providing services to acquire covered Russian metals as part of a physically settled derivative contract (i.e., the expiration of the contract results in a transfer of ownership of the physical commodity, as opposed to a cash settled derivatives contract in which the derivative expires directly into cash on the maturity date of the trade).  In addition, a U.S. trader that is a counterparty to a derivative contract cannot take physical delivery of covered Russian metals when it comes time to settle that contract, even if the importation of the metal would not be into the United States. 

As noted above, the Metals Services Determination does not impose any prohibitions on services related to aluminum, copper, or nickel of Russian Federation origin that was produced prior to April 13, 2024.  For example, aluminum, copper, and nickel of Russian Federation origin that is already warranted as of April 13, 2024 on a global metal exchange can continue to be traded, and new warranting and trading can continue for aluminum, copper, and nickel of Russian Federation origin that was produced prior to April 13, 2024, including through new derivatives contracts.  Market participants and traders may reasonably rely on the Certificate of Analysis and Certificate of Origin of the relevant Russian metal, or other documentation available to them in the ordinary course of business, with respect to the date of production, but should exercise caution if they have reason to believe such documentation has been falsified or is otherwise erroneous.  

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On December 6, 2023, and February 24, 2024, the G7 Leaders issued statements signaling their intent to reduce Russia’s revenues from metals.  On April 12, 2024, in coordination with the United Kingdom, the United States issued two new prohibitions that will further disrupt the revenue that Russia earns from its export of aluminum, copper, and nickel of Russian Federation origin, including through the use of U.S. global metal exchanges.

To implement this action, Treasury issued two determinations.  The first, “Prohibitions Related to Imports of Aluminum, Copper, and Nickel of Russian Federation Origin” (the “Metals Import Determination”) pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114, prohibits the importation and entry into the United States, including importation for admission into a foreign trade zone located in the United States, of aluminum, copper, and nickel of Russian Federation origin.  Per the determination, the importation into the United States of aluminum, copper, and nickel of Russian Federation origin that was produced prior to April 13, 2024 is not prohibited.  See FAQ 1019 and 1170 for more information.

The second, “Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin” (the “Metals Services Determination”) pursuant to E.O. 14071, prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of the following categories of services to any person located in the Russian Federation:  warranting services for aluminum, copper, or nickel of Russian Federation origin on a global metal exchange; and services to acquire aluminum, copper, or nickel of Russian Federation origin, as part of the physical settlement of a derivative contract (collectively, “Covered Metals Acquisition Services”).  This determination does not apply to services related to aluminum, copper, or nickel of Russian Federation origin that was produced prior to April 13, 2024.  See FAQs 1169, 1170, 1128, 1019, and FAQ 1058 for more information. 

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On February 29, 2024, OFAC issued Venezuela GL 45B, “Authorizing Certain Repatriation Transactions Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A.,” which narrowed the scope of transactions previously authorized by GL 45A.  GL 45B no longer authorizes transactions ordinarily incident and necessary to non-commercial flights (i.e., not-for-profit flights that are not intended to generate a profit for Conviasa) between non-U.S. jurisdictions in the Western Hemisphere and Venezuela that are not exclusively for the purposes of repatriation. In addition, OFAC is removing the Annex and authorization related to the general maintenance (including repair) of aircraft previously listed in it, limiting the authorization for general maintenance to the aircraft being used for repatriation flights.

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The Diamond Jewelry Determination prohibits the importation and entry into the United States of diamond jewelry and unsorted diamonds of Russian Federation origin, as well as diamond jewelry and unsorted diamonds that were exported from the Russian Federation.  For example, it prohibits the importation into the United States of a diamond bracelet that has been manufactured in the Russian Federation, regardless of where the diamonds originated.

This prohibition comes into effect on March 1, 2024.  See FAQ 1027 for the definition of diamond jewelry.  See FAQ 1019 for the definition of Russian Federation origin.  See FAQ 1165 for information on the prohibition related to certain categories of non-industrial diamonds. 

Date updated: March 04, 2024

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The Diamonds Determination prohibits the importation and entry into the United States of two categories of diamonds, effective on the dates indicated below.  

Effective March 1, 2024, the Diamonds Determination prohibits the importation of non-industrial diamonds that were mined, extracted, produced, or manufactured wholly or in part in the Russian Federation with a weight of 1.0 carat or greater, even if such diamonds have been substantially transformed into other products outside of the Russian Federation.    

Effective September 1, 2024, the Diamonds Determination prohibits the importation of Russian non-industrial diamonds with a weight of 0.5 carats or greater, even if such diamonds have been substantially transformed into other products outside of the Russian Federation.

For example, a non-industrial diamond that is mined in Russia but then undergoes manufacturing operations such as being cut, faceted, or polished in a third country, is prohibited from importation and entry into the United States, if at the time of importation, it is 1.0 carat or greater as of March 1, 2024 or 0.5 carats or greater as of September 1, 2024.  

See FAQ 1027 for the definition of non-industrial diamonds.  See FAQ 1166 for information on the prohibition related to diamond jewelry and unsorted diamonds.

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On March 11, 2022, the Biden Administration issued Executive Order (E.O.) 14068, prohibiting the importation into the United States of non-industrial diamonds of Russian Federation origin.  See FAQs 1019 and 1027 for the definition of Russian Federation origin and non-industrial diamonds, respectively.  On December 6, 2023, the G7 Leaders announced a coordinated international effort to impose phased restrictions on the importation of certain Russian diamonds, including diamonds processed in third countries.  As a part of this G7 commitment, OFAC has issued additional restrictions on the importation of non-industrial diamonds mined, extracted, produced, or manufactured wholly or in part in the Russian Federation as well as unsorted diamonds and diamond jewelry.

Specifically, on February 8, 2024, OFAC issued two determinations, “Prohibitions Related to Imports of Certain Categories of Diamonds” pursuant to Executive Order (E.O.) 14068 (the “Diamonds Determination”) and “Prohibitions Related to Imports of Diamond Jewelry  and Unsorted Diamonds of Russian Federation Origin and Diamond Jewelry and Unsorted Diamonds Exported From the Russian Federation” pursuant to Executive Order (E.O.) 14068 (the “Diamond Jewelry and Unsorted Diamonds Determination”).  These prohibitions are described below, along with the relevant Harmonized Tariff Schedule of the United States (HTSUS) references and a list of illustrative examples of products subject to the prohibitions. 

 
Import ProhibitionEffective DateIllustrative Example and Relevant HTSUS ReferencesAdditional Information and Guidance
Non-industrial diamonds of Russian Federation origin (any weight)March 11, 2022

Non-industrial diamonds that are products of Russia

HTSUS Subheading: 7102.31, 7102.39

See E.O. 14068; FAQs 1024 and 1027
Non-industrial diamonds of Russian Federation origin, regardless of whether such diamonds have been substantially transformed in third countries

March 1, 2024: ≥ 1.0 carat


September 1, 2024:  ≥ 0.5 carat

Rough diamond was mined in Russia then cut and polished in a third country

HTSUS Subheading: 7102.31, 7102.39

See the Diamonds Determination; FAQs 1027, 1154, and 1165
Unsorted diamonds of Russian Federation origin or exported from RussiaMarch 1, 2024

Unsorted diamonds mined or exported from Russia

HTSUS Subheading: 7102.10

See the Diamond Jewelry and Unsorted Diamonds Determination; FAQs 1027, 1154, and 1166
Diamond jewelry of Russian Federation origin or exported from RussiaMarch 1, 2024

Diamond bracelet either made in Russia or made elsewhere but exported from Russia

HTSUS Heading: 7113, incorporating diamonds

See the Diamond Jewelry and Unsorted Diamonds Determination; FAQs 1027, 1154, and 1166

 

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No.  The general license for the exportation or reexportation of certain agricultural and medical items at § 510.521 of the North Korea Sanctions Regulations, 31 CFR part 510, does not authorize the exportation or reexportation to North Korea of luxury goods, including tobacco, as set forth in 15 CFR § 746.4(b)(1) of the Export Administration Regulations (15 CFR parts 730 through 774). 

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To be eligible for the NGO GL, an NGO must first submit a report to the U.S. Department of State via email to DPRK-NGO-GL-Notification-DL@state.gov no fewer than 30 days before the commencement of their activities, with one of the following:  (1) a copy of approval by the UN Security Council 1718 Committee (1718 Committee) with respect to the NGO’s activities; (2) a copy of a 1718 Committee exemption request or notification that has been or will be submitted to the 1718 Committee with respect to the NGO’s activities; or (3) a detailed explanation of why the NGO’s proposed activities do not require such an exemption or notification, including details about the type and scope of the proposed activities.  In the two-week period following submission of this information, the U.S. Department of State may notify the NGO that it is not eligible to rely upon the GL.  An NGO that does not receive this type of notification may proceed with the activities described in the report. 

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Yes, subject to certain conditions and limitations.  NGOs may engage in transactions with the Government of North Korea to the extent ordinarily incident and necessary to the activities authorized by § 510.512(a).  Such transactions may not include partnerships and partnership agreements with Government of North Korea military, intelligence, or law enforcement entities, except as necessary to export or import items to or from North Korea that are licensed or otherwise authorized pursuant to the NKSR or pursuant to the Export Administration Regulations (15 CFR parts 730 through 774) (EAR).  For example, NGOs may engage with North Korea’s Ministry of Public Health to provide assistance to clean water projects; with customs officials to import humanitarian-related items into the country; and with local jurisdictions, such as city governments and hospitals, to provide food and medical devices.  However, this general license does not authorize the exportation or reexportation of services to, charitable donations to or for the benefit of, or any other transactions involving, the Government of North Korea, the Workers’ Party of Korea, or any other person whose property and interests in property are blocked pursuant to the NKSR, except as ordinarily incident and necessary to an activity authorized pursuant to § 510.512(a). 

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On February 15, 2024, OFAC, in consultation with the Department of State, amended the NKSR to modify an existing general license (GL) and add three new GLs to facilitate humanitarian-related and other activities in North Korea.  These changes include:

  • Additional non-governmental organization (NGO) activities

OFAC amended the GL at § 510.512 to authorize NGOs to engage in a broader range of humanitarian-related activities involving North Korea, including certain educational activities and activities to support disarmament, demobilization, and reintegration (DDR) programs and peacebuilding, conflict prevention, and conflict resolution programs.  The general license at § 510.512 allows transactions that are ordinarily incident and necessary to such NGO activities involving certain Government of North Korea entities, including limited partnerships, subject to certain conditions and limitations–including that the NGO must submit a report to the U.S. Department of State at least 30 days before their proposed activities, as further described in FAQ 1162.

The amended NGO GL at § 510.512 authorizes the export and reexport to North Korea of items not subject to the Export Administration Regulations (15 CFR parts 730 through 774) (EAR) to North Korea that are ordinarily incident and necessary to authorized NGO activities, provided the items would be designated as EAR99 if located in the United States.

  • Removal of dual licensing burden

To avoid duplicative licensing requirements, OFAC added a new GL at § 510.520 to authorize all transactions ordinarily incident to the exportation or reexportation of items (i.e., commodities, software, or technology) to North Korea, provided the exportation or reexportation is licensed or otherwise authorized by the Department of Commerce.  Such transactions may include transactions with the Government of North Korea, or any other person blocked pursuant to the NKSR, and services provided outside North Korea to install, repair, or replace authorized items.  Accordingly, U.S. persons no longer need to seek a specific license from OFAC to engage in transactions ordinarily incident to exports and reexports that are already licensed or otherwise authorized by the Department of Commerce.

  • Expansion of authorization for the exportation or reexportation of certain food, medicine, and other agricultural and medical items

OFAC added a new GL at § 510.521 to authorize certain transactions related to the export and reexport to North Korea of certain agricultural commodities (including food), medicine, medical devices, and replacement parts and components for medical devices, that are not subject to the EAR but that would be designated EAR99 if they were located in the United States, subject to certain conditions and limitations.

  • Journalistic activities

OFAC added a new GL at § 510.522 to authorize U.S. news reporting organizations and certain of their U.S. person employees to engage in certain transactions ordinarily incident and necessary to their journalistic activities or the establishment or operation of a news bureau in North Korea.
 

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Wind down transactions:  GL 27 authorizes all transactions prohibited by the GTSR that are ordinarily incident and necessary to the wind down of any transaction involving Fly Baghdad through 12:01 a.m. eastern daylight time, March 22, 2024, provided that any payment to Fly Baghdad must be made into a blocked account in accordance with the GTSR.  This includes transactions necessary to wind down leases, refueling contracts, and other commercial agreements with Fly Baghdad or to repossess aircraft leased to Fly Baghdad. 
U.S. persons are not required to seek a license from OFAC to initiate legal proceedings against Fly Baghdad, including lawsuits for the repossession of aircraft from Fly Baghdad, although a specific license is required to enter into a settlement or enforce an order transferring property blocked pursuant to the GTSR. 
Civil aviation safety transactions:  GL 27 authorizes all transactions prohibited by the GTSR that are ordinarily incident and necessary to the provision, exportation, or re-exportation of goods, technology, or services to ensure the safety of civil aviation involving Fly Baghdad through 12:01 a.m. eastern daylight time, March 22, 2024, provided that the goods, technology, or services are for use on aircraft operated solely for civil aviation purposes.  This includes transactions necessary to ensure the safety of aircraft crew and passengers and the safe operation of aircraft owned or operated by Fly Baghdad and used solely for civil aviation purposes, including maintenance, insurance, and ground services ordinarily incident and necessary to such activities. 
U.S. and non-U.S. persons may need to obtain a license from the Department of Commerce’s Bureau of Industry and Security (BIS) for the export or reexport or certain items subject to the Export Administration Regulations (EAR) involving Fly Baghdad or other Specially Designated Global Terrorists (SDGTs).  For further guidance regarding the exportation or re-exportation of items involving SDGTs, please contact BIS at Foreign.Policy@bis.doc.gov.

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Following the designation of Ansarallah (commonly referred to as “the Houthis”) under E.O. 13224, as amended, on February 16, 2024, OFAC will add the group to the List of Specially Designated Nationals and Blocked Persons (SDN List) as a Specially Designated Global Terrorist.  As a result of the designation, transactions by U.S. persons or within (or transiting) the United States involving Ansarallah will be blocked, unless they are otherwise authorized.  Note that Yemen is not subject to jurisdiction-based sanctions, nor will it become subject to jurisdiction-based sanctions on February 16, 2024. 

In order to ensure that the humanitarian aid community and commercial actors can continue providing humanitarian aid and commercial goods in Yemen, on January 17, 2024, OFAC issued five general licenses (GLs) to authorize certain categories of transactions, including:  (1) agriculture, medicine, and medical devices; (2) telecommunications mail, and certain internet communications; (3) personal remittances; (4) refined petroleum products (including fuel); and (5) operation and use of ports and airports for import of goods.  These GLs will take effect on February 16, 2024, the same date on which the designation will take effect. 

The above GLs supplement broad preexisting humanitarian GLs in the Global Terrorism Sanctions Regulations (GTSR) covering the United States government, certain international organizations and entitiesnongovernmental organizations (NGOs), and for the provision of food, other agricultural commodities, medicine, and medical devices.  For more information on these baseline humanitarian general licenses, please consult OFAC’s  Supplemental Guidance for the Provision of Humanitarian Assistance, and FAQs 110511061107, and 1108.  Other humanitarian-related guidance documents are available in the NGO section of OFAC’s Information for Industry Groups webpage.  OFAC also intends to issue further public guidance specifically related to the Ansarallah designation on or before February 16, 2024.

Non-U.S. persons may engage in or facilitate transactions for which a U.S. person would not require a specific license pursuant to the GTSR without exposure to sanctions under the GTSR or E.O. 13224, as amended.

OFAC prioritizes specific license applications and requests for guidance related to humanitarian activity.  OFAC encourages anyone with questions to reach out to the OFAC Compliance Hotline directly via phone at (800) 540-6322 or (202) 622-2490 or email OFAC_Feedback@treasury.gov

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For the purposes of the Seafood Determination, OFAC anticipates publishing regulations defining these terms to include articles defined at the following Harmonized Tariff Schedule of the United States (HTSUS) subheadings: 
•    “Salmon:” articles defined at HTSUS subheadings 0302.13.0013, 0302.13.0014, 0302.13.0022, 0302.13.0032, 0302.13.0042, 0302.13.0053, 0302.13.0054, 0302.13.0062, 0302.14.0003, 0302.14.0004, 0302.14.0062, 0303.11.0000, 0303.12.0012, 0303.12.0022, 0303.12.0032, 0303.12.0052, 0303.12.0062, 0303.13.0000, 0303.91.4040, 0304.41.00, 0304.41.0010, 0304.41.0020, 0304.41.0090, 0304.52.00, 0304.52.0010, 0304.52.0015, 0304.52.0020, 0304.52.0090, 0304.81.1000, 0304.81.5010, 0304.81.5090, 0305.20.4020, 0305.41.0000, 0305.69.4000, 1604.11.2020, 1604.11.2030, 1604.11.2090, 1604.11.4010, 1604.11.4020, 1604.11.4030, 1604.11.4040, 1604.11.4050, including any subsequent revisions to the list of HTSUS classifications.
•    “Cod:” articles defined at HTSUS subheadings 0302.51.0010, 0302.51.0090, 0303.63.0010, 0303.63.0090, 0304.44.0010, 0304.44.0015, 0304.53.0010, 0304.53.0015, 0304.71.1000, 0304.71.5000, 0304.95.1010, 0304.95.1015, 0304.95.1020, 0305.32.0010, 0305.32.0090, 0305.51.0000, 0305.62.0010, 0305.62.0025, 0305.62.0030, 0305.62.0045, 0305.62.0050, 0305.62.0060, 0305.62.0070, 0305.62.0080, including any subsequent revisions to the list of HTSUS classifications.
•    “Pollock:” articles defined at HTSUS subheadings 0302.55.1100, 0302.55.5000, 0302.59.5010, 0303.67.0000, 0304.44.0025, 0304.53.0025, 0304.75.1000, 0304.75.5000, 0304.79.1010, 0304.94.1005, 0304.94.1010, 0304.94.1090, 0304.94.9000, 0304.95.1030, 0305.69.1022, 0305.69.1042, 1604.19.1000, 1604.19.2500, including any subsequent revisions to the list of HTSUS classifications.
•    “Crab:” articles defined at HTSUS subheadings 0306.14.2000, 0306.14.40, 0306.14.4003, 0306.14.4006, 0306.14.4009, 0306.14.4012, 0306.14.4015, 0306.14.4020, 0306.14.4030, 0306.14.4090, 0306.33.2000, 0306.33.4000, 0306.93.2000, 0306.93.4000, 1605.10.0510, 1605.10.0590, 1605.10.2010, 1605.10.2022, 1605.10.2025, 1605.10.2030, 1605.10.2051, 1605.10.2059, 1605.10.2090, 1605.10.4002, 1605.10.4005, 1605.10.4010, 1605.10.4015, 1605.10.4025, 1605.10.4030, 1605.10.4035, 1605.10.4040, 1605.10.6010, 1605.10.6090, including any subsequent revisions to the list of HTSUS classifications.
Additionally, these terms apply to products of salmon, cod, pollack and crab classified under the HTSUS subheadings 0301.99.0390, 0302.59.1100, 0304.95.1005, 0304.95.1090, 0304.99.1104, 0304.99.1109, 0304.99.1183, 0305.20.4065, 0305.39.6180, 0305.49.4020, 0305.49.4045, 0305.59.0001, 0305.72.0000, 0305.79.0000, 1603.00.9090, 1604.19.2200, 1604.19.3200, 1604.19.4100, 1604.19.5100, 1604.19.6100, 1604.19.8200, 1604.20.0510, 1604.20.0590, 1604.20.1000, 1604.20.1500, 1604.20.2000, 1604.20.2500, 1604.20.3000, 1604.20.4000, 1604.20.5010, 1604.20.5090, 1604.20.6010, 1604.20.6090, including any subsequent revisions to the list of HTSUS classifications.

Date Updated: January 18, 2024

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Individuals and entities may import the listed types of seafood, for a limited time, into the United States subject to the conditions of General License (GL) 83.  GL 83 authorizes the importation into the United States, through 12:01 a.m. eastern standard time, February 21, 2024, of salmon, cod, pollock, and crab that are subject to the Seafood Determination, provided that the importation is pursuant to written contracts or written agreements entered into prior to December 22, 2023. 

Individuals and entities may also find new buyers or re-direct such shipments to other countries.  The Seafood Determination prohibits the importation into the United States of salmon, cod, pollock, or crab of Russian Federation origin, even if incorporated or substantially transformed into another product in a third country.  It does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments outside the United States that were previously destined for the United States.

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The Seafood Determination issued pursuant to subsection 1(a)(i)(B) of E.O. 14068, as amended, prohibits the importation and entry into the United States, including importation for admission into a foreign trade zone located in the United States, of salmon, cod, pollock, or crab that was produced wholly or in part in the Russian Federation or harvested in waters under the jurisdiction of the Russian Federation or by Russia-flagged vessels, even if such salmon, cod, pollock, or crab has been incorporated or substantially transformed into another product outside of the Russian Federation. 

Accordingly, the Seafood Determination expands the importation prohibitions in E.O. 14068 to include salmon, cod, pollock, or crab of Russian Federation origin that have been processed in a third country into a new product. 

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E.O. 14114 of December 22, 2023 amends E.O. 14068 to provide for additional prohibitions on the importation and entry into the United States of certain products.  It does so by maintaining the existing E.O. 14068 importation prohibitions in subsection 1(a)(i)(A) and identifying in subsections 1(a)(i)(B)–(D) additional types of products that may be prohibited upon the issuance of determinations, as described below. 

Subsection 1(a)(i)(B) authorizes the imposition of importation prohibitions on categories of fish, seafood, and preparations thereof, diamonds, and other products as may be determined, that were mined, extracted, produced, or manufactured wholly or in part in the Russian Federation, or harvested in waters under the jurisdiction of the Russian Federation or by Russia-flagged vessels, even if such products have been incorporated or substantially transformed into other products outside of the Russian Federation. 

Subsections 1(a)(i)(C) and (D) authorize the identification of additional types of products that would be subject to importation prohibitions under the order, upon a determination by the Secretary of the Treasury, in consultation with the Secretary of State, Secretary of Commerce, and Secretary of Homeland Security.

For additional information and guidance on the amendment to E.O. 14068, see FAQs 1155, 1156, 1157, 1164, 1165, and 1166. 
 

Date Updated: February 23, 2024

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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 a significant transaction denominated in a non-USD local currency for a person blocked pursuant to E.O. 14024 or 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

Updated: June 12, 2024

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OFAC expects to promulgate regulations that define or interpret these terms as follows:

Foreign Financial Institution: As defined in subsection 11(f) of E.O. 14024, foreign financial institution means any foreign entity that is engaged in the business of accepting deposits, making, granting, transferring, holding, or brokering loans or credits, or purchasing or selling foreign exchange, securities, futures or options, or procuring purchasers and sellers thereof, as principal or agent.  It includes depository institutions, banks, savings banks, money services businesses, operators of credit card systems, trust companies, insurance companies, securities brokers and dealers, futures and options brokers and dealers, forward contract and foreign exchange merchants, securities and commodities exchanges, clearing corporations, investment companies, employee benefit plans, dealers in precious metals, stones, or jewels, and holding companies, affiliates, or subsidiaries of any of the foregoing.  The term does not include the international financial institutions identified in 22 U.S.C. 262r(c)(2), the International Fund for Agricultural Development, the North American Development Bank, or any other international financial institution so notified by the Office of Foreign Assets Control.

Russia’s military-industrial base includes all persons blocked pursuant to E.O. 14024, as well as any person operating in the technology, defense and related materiel, construction, aerospace, and manufacturing sectors of the Russian Federation economy (and other sectors as may be determined pursuant to E.O. 14024).  For definitions of those identified sectors, see FAQ 1126.  Russia’s military-industrial base may also include individuals and entities that support the sale, supply, or transfer, directly or indirectly, of critical items identified in determinations pursuant to subsection 11(a)(ii) of E.O. 14024, to the Russian Federation.  See determination of December 22, 2023 pursuant to subsection 11(a)(ii) of Executive Order 14024 (Russia Critical Items Determination). See also FAQ 1150 for additional information. 

Significant transaction or transactions: OFAC may consider the totality of the facts and circumstances when determining whether a transaction or transactions are “significant.”  As a general matter, some or all of the following factors may be considered:  (a) the size, number, and frequency of the transaction(s); (b) the nature of the transaction(s); (c) the level of awareness of management and whether the transactions are part of a pattern of conduct; (d) the nexus of the transaction(s) to persons sanctioned pursuant to E.O. 14024, or to persons operating in Russia’s military-industrial base; (e) whether the transaction(s) involve deceptive practices; (f) the impact of the transaction(s) on U.S. national security objectives; and (g) such other relevant factors that OFAC deems relevant.

Updated: June 12, 2024

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The Russia Critical Items Determination issued pursuant to subsection 11(a)(ii) of E.O. 14024 identifies certain items that support Russia’s military-industrial base.  Foreign financial institutions (FFIs) may be sanctioned for having conducted or facilitated any significant transaction or transactions, or provided any service, involving Russia’s military-industrial base, including the sale, supply, or transfer, directly or indirectly of these identified items.

FFIs should use the list of specified items for the purpose of mitigating sanctions risk under section 11 of E.O. 14024, as amended.  The broader groups in which these items are categorized provide additional context as to why they are critical for Russia’s war effort, including for the production of advanced precision-guided weapons and other critical items.  OFAC’s Advisory to Foreign Banks on Russia Sanctions Risks provides additional guidance to FFIs on the use of the specified items in the Russia Critical Items Determination and the U.S. Department of Commerce’s Common High Priority Items List.

Russia Critical Items Determination

 
 Items determined pursuant to E.O. 14024, Sec. 11(a)(ii)
Certain machine tools and manufacturing equipment Numerically controlled (CNC) machine tools
Additive manufacturing (AM) machine tools
Semiconductor manufacturing equipment
Certain manufacturing materials for semiconductors and related electronics Silicon boules
Silicon wafers
Photoresist materials
Bare printed circuit boards (PCBs)
Printed circuit board (PCB) substrates
Certain electronic test equipmentOscilloscopes
Automated test equipment
Data acquisition systems
Signal generators
Pulse generators
Spectrum analyzers
Certain propellants, chemical precursors for propellants and explosivesNitrocellulose 
Smokeless powder
Research Department eXplosive (RDX, also known as Royal Demolition eXplosive, cyclonite, hexogen)  
High Melting eXplosive (HMX, also known as High-Molecular-Weight RDX, octogen, cyclotetramethylenetetranitramine)
Certain lubricants and lubricant additivesTurbine oil 
Turbine oil additives 
Certain bearingsHigh-precision ball and roller bearings
Angular contact (spindle) bearings
Certain advanced optical systemsThermal sights
Thermal imaging arrays
Infrared focal plane arrays
Image intensifier tubes (ITTs)
Certain navigation instrumentsInertial navigation systems (INS)
Inertial measurement units (IMUs)
Fiber-optic gyroscopes (FOGs)
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Pursuant to subsection 11(b) of E.O. 14024, as amended, OFAC may block FFIs or prohibit the opening or prohibit or impose strict conditions on the maintenance of correspondent accounts or payable-through accounts in the United States for such FFIs.

For FFIs for which the opening or maintaining of a correspondent account or a payable-through account is prohibited pursuant to subsection 11(b)(i) of E.O. 14024, U.S. financial institutions must close any correspondent account or payable-through account maintained for or on behalf of those foreign financial institutions.  Russia-related General License (GL) 84 authorizes the closures of such accounts within 10 days of the imposition of sanctions pursuant to subsection 11(b)(i) of E.O. 14024, subject to certain conditions.

For FFIs subject to blocking sanctions pursuant to subsection 11(b)(ii) of E.O. 14024, all property and interests in property of those FFIs that are in the United States or in possession or control of U.S. persons are blocked and must be reported to OFAC.  Any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked FFIs (or other blocked persons) are also blocked.  

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FFIs may be sanctioned for engaging in certain transactions, or providing any service, involving Russia’s military-industrial base.  For example, FFIs may be sanctioned for conducting any significant transaction(s) for any person that has been blocked pursuant to E.O. 14024.  FFIs may also be sanctioned for maintaining accounts, transferring funds, or providing other financial services to persons, either inside or outside Russia, for any person blocked pursuant to E.O. 14024, as well as to any person operating in the following sectors of the Russian Federation economy: technology, defense and related materiel, construction, aerospace, or manufacturing. This also includes facilitating the sale, supply, or transfer, directly or indirectly, to the Russian Federation of certain items critical to Russia’s war effort identified in the determination of December 22, 2023 pursuant to subsection 11(a)(ii) of E.O. 14024 (Russia Critical Items Determination), such as certain machine tools, semiconductor manufacturing equipment, electronic test equipment, propellants and their precursors, lubricants and lubricant additives, bearings, advanced optical systems, and navigation instruments.

For additional information and examples of the types of activities that would expose FFIs to sanctions risks, see OFAC’s Advisory to Foreign Banks on Russia Sanctions Risks. For additional information on the specific items identified on the Russia Critical Items Determination, see FAQ 1150.

Updated: June 12, 2024
 

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E.O. 14114 amends E.O. 14024 to authorize the imposition of sanctions on foreign financial institutions (FFIs) that have engaged in certain transactions involving Russia’s military-industrial base, including all persons whose property and interests in property are blocked pursuant to E.O. 14024.  Specifically, section 11 of E.O. 14024, as amended, authorizes sanctions on FFIs that have (i) conducted or facilitated any significant transaction or transactions for or on behalf of any person designated pursuant to E.O. 14024 for operating or having operated in the technology, defense and related materiel, construction, aerospace, or manufacturing sectors of the Russian Federation economy or other sectors as may be determined to support Russia’s military-industrial base by the Secretary of the Treasury, in consultation with the Secretary of State; or (ii) conducted or facilitated any significant transaction or transactions, or provided any service, involving Russia’s military-industrial base, including the sale, supply, or transfer, directly or indirectly, to the Russian Federation, of any item or class of items as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Commerce.  See determination of December 22, 2023 pursuant to subsection 11(a)(ii) of E.O. 14024 (Russia Critical Items Determination) for the list of items determined under the order, as amended.

Subsection 11(b) of E.O. 14024, as amended, authorizes OFAC (i) to prohibit the opening or prohibit or impose strict conditions on the maintenance of correspondent accounts or payable-through accounts in the United States for such FFIs or (ii) to block such FFIs.

For additional information and guidance on the amendment to E.O. 14024, see FAQs 1148, 1149, 1150, 1151, 1152, 1153, 1181, and 1182

Updated: June 12, 2024

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E.O. 14114 amends E.O. 14024 and E.O. 14068 to further address the Russian Federation’s continued use of its military-industrial base to aid its effort to undermine security in countries and regions important to United States national security and to further counteract the Russian Federation’s continued evasion of U.S. sanctions.  For additional information and guidance on the amendment to E.O. 14024, see FAQs 1147, 1148, 1149, 1150, 1151, 1152, 1181, and 1182. For additional information on the amendment to E.O. 14068, see FAQs 1154, 1155, 1156, and 1157.

Updated: June 12, 2024

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Generally, the designation of an individual with a leadership role in a governing institution does not itself block the governing institution.  Accordingly, engaging in a routine interaction with a governing institution in which a blocked individual is an official, but that does not directly or indirectly involve the blocked individual in question, is not prohibited.  This applies to any designated individual in Afghanistan who has a leadership role in a governing institution in Afghanistan, including any individual blocked pursuant to the Global Magnitsky Sanctions Regulations (GMSR).  For example, making a customs payment to a governing institution in Afghanistan led by a blocked individual would not be prohibited by the GMSR.  However, engaging directly or indirectly with that blocked individual, such as receiving an invoice bearing the blocked individual’s signature for a commercial transaction, would be prohibited by the GMSR unless authorized by OFAC or exempt.

In addition, certain humanitarian-related transactions involving individuals blocked pursuant to the GMSR may be authorized by general licenses (GL) in the GMSR related to certain international organizations (IOs), nongovernmental organizations (NGOs), official business of the United States government (USG), or agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for personal, non-commercial use (Ag-Med).  For more information on these GLs, please consult OFAC ‘s Supplemental Guidance for the Provision of Humanitarian Assistance and FAQs 1105, 1106, 1107, 1108.

For information on transactions involving governing institutions in Afghanistan led by an individual or entity designated under the Global Terrorism Sanctions Regulations, the Foreign Terrorist Organizations Sanctions Regulations, or Executive Order 13224, please consult Afghanistan-related GL 20 and FAQ 993.

If individuals or entities, including IOs, NGOs, or financial institutions, have questions about engaging in or processing transactions related to these authorizations, they can contact the OFAC Compliance Hotline via email at OFAC_Feedback@treasury.gov.

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Yes.  As a general matter, humanitarian trade is not the target of U.S. sanctions.  Concurrent with the designation of Orka Holding AD, OFAC issued Western Balkans General License (GL) 3, which authorizes all transactions involving Orka Holding AD related to:  (1) the production, manufacturing, sale, transport, or provision of agricultural commodities, agricultural equipment, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices; (2) the prevention, diagnosis, or treatment of any disease or medical condition; or (3) the conducting of clinical trials or other medical research.  Importantly, the authorization also applies to any entity in which Orka Holding AD owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.

Non-U.S. persons generally do not risk exposure to sanctions for engaging in transactions with blocked persons where those transactions would not require a specific license if engaged in by a U.S. person.  As such, non-U.S. persons generally would not face sanctions risk for engaging in activities authorized for U.S. persons by Western Balkans GL 3.

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Yes.  The prohibitions in the MOGE Financial Services Directive apply to MOGE “or its property or interests in property,” including any entity, such as a subsidiary or joint venture, that is 50 percent or more owned, directly or indirectly, by MOGE, except to the extent otherwise provided by law or unless authorized by OFAC.

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Pursuant to the MOGE Financial Services Directive, the following activities by a U.S. person are prohibited on or after December 15, 2023:  the provision, exportation, or rexportation, directly or indirectly, of financial services to or for the benefit of Myanma Oil and Gas Enterprise (MOGE).

Further, except to the extent otherwise provided by law or unless authorized by OFAC, the following are also prohibited pursuant to the MOGE Financial Services Directive:  (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the MOGE Financial Services Directive; and (2) any conspiracy formed to violate any of the prohibitions of the MOGE Financial Services Directive.

OFAC considers the term “financial services” for purposes of the MOGE Financial Services Directive to include loans, transfers, accounts, insurance, investments, securities, guarantees, foreign exchange, letters of credit, and commodity futures or options.

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For the purposes of GL 45B, OFAC considers the term “Western Hemisphere” to mean those countries and areas identified by the Department of State on its website as comprising the Western Hemisphere.  Please see:  Bureau of Western Hemisphere Affairs - United States Department of State.

Date updated: March 01, 2024

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Yes.  On October 18, 2023, OFAC issued amended General Licenses (GLs) 3I and 9H, to remove the restriction that any divestment by U.S. persons of holdings in GL 3I Bonds (as defined in GL 3I and FAQ 662) or PdVSA Securities (as defined in GL 9H and FAQ 661) must be to non-U.S. persons.

GL 3I replaces and supersedes in its entirety GL 3H, which did not authorize U.S. persons to purchase or invest in, or to facilitate the purchase of or investment in, directly or indirectly, the bonds specified in the Annex to GL 3H, with certain exceptions.  Under GL 3I, U.S. persons are no longer subject to the restriction that any divestment of holdings in GL 3I Bonds must be to non-U.S. persons.  For more information on GL 3I, please see FAQ 662. 

GL 9H replaces and supersedes in its entirety GL 9G, which did not authorize U.S. persons to purchase or invest in, or to facilitate the purchase of or investment in, directly or indirectly, PdVSA Securities, with certain exceptions.  Under GL 9H, U.S. persons are no longer subject to the restriction that any divestment of holdings in PdVSA Securities must be to non-U.S. persons.   

All sanctions related to the primary bond market remain in place.

For more information on GL 9H, please see FAQ 661.

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Financial institutions participating in the humanitarian channel in Qatar (HC) have received specific guidance from the U.S. government.  Companies interested in participating in transactions under the HC should coordinate directly with the Qatari International Media Office at info@imo.gov.qa and should not hesitate to contact the OFAC Compliance Hotline with specific questions.

OFAC’s requirements related to humanitarian trade with Iran have not changed.  Companies interested in participating in transactions pursuant to existing exceptions and authorizations for the conduct of humanitarian trade with Iran may continue to do so outside of the HC.  For example, certain humanitarian transactions involving the Central Bank of Iran and the National Iranian Oil Company are permissible under General License 8A (see also FAQ 823).  OFAC FAQ 828 and our Guidance on the Sale of Food, Agricultural Commodities, Medicine, and Medical Devices by Non-U.S. Persons to Iran reflect OFAC’s longstanding regulations related to exports of humanitarian goods to Iran.  Iranian financial institutions designated under Executive Order (E.O.) 13902 are subject to the exception in E.O. 13902 with respect to conducting or facilitating transactions for the provision (including any sale) of agricultural commodities, food, medicine, or medical devices to Iran.

U.S. persons and their owned or controlled foreign entities must continue to comply with the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), when conducting exports of humanitarian goods to Iran.  Certain exports and sales of humanitarian goods to Iran are authorized pursuant to sections 560.530, 560.532, and 560.533 of the ITSR.

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The humanitarian channel in Qatar (HC) was established to further facilitate the flow of humanitarian assistance to the people of Iran consistent with the U.S. government’s longstanding support for humanitarian trade.  Similar to humanitarian channels established under previous administrations, the HC is designed to support the Iranian people’s access to food, agricultural goods, medicine, and medical devices under stringent due diligence measures that guard against money laundering, misuse, and evasion of U.S. sanctions.

The HC offers a voluntary option for facilitating payments for humanitarian exports to Iran, but parties may continue to avail themselves of existing exceptions and authorizations to conduct humanitarian trade with Iran outside of the channel.  The United States has long maintained broad exceptions and authorizations for the sale of food, agricultural commodities, medicine, and medical devices to Iran by U.S. and non-U.S. persons.  OFAC’s Guidance on the Sale of Food, Agricultural Commodities, Medicine, and Medical Devices by Non-U.S. Persons to Iran reflects longstanding regulations related to exports of humanitarian goods to Iran.  These exceptions and authorizations are also clearly stated on the Iran Sanctions Program website maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control.

The HC has not and does not allow funds to be released to the Government of Iran or payments to Iranian companies.  In partnership with the Government of Qatar and financial institutions operating the HC — all of which have committed to stringent due diligence measures — the United States will closely monitor the HC and will take appropriate action should Iran attempt to use these funds for purposes other than permitted humanitarian purchases.  The HC does not lift any U.S. sanctions on Iran, and the U.S. government continues to impose sanctions on Iran’s malign activity, including in response to Iran’s weapons proliferation and its support for international terrorism.

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For the purposes of the determination of August 23, 2023 made pursuant to E.O. 14014, OFAC interprets the term “jet fuel sector of the Burmese economy” to include activities related to the importation, exportation, reexportation, sale, supply, or transport, directly or indirectly, of jet fuel in or involving Burma.

OFAC does not intend to target persons for engaging in activities related to civil aviation, including the sale, provision, or purchase of jet fuel to or for commercial airlines for air transport to and from Burma.  Rather, OFAC intends to target activities for or related to military regime end users in Burma, wherever situated (e.g., jet fuel used for military resupply aircraft, state-owned aircraft used by members of the military regime, and combat vehicles, including jets and attack helicopters, used in both offensive and defensive military operations inside Burma).  Anyone supplying jet fuel to individuals or entities in Burma should exercise extreme caution to ensure jet fuel is provided only for use in civil aviation and not to military regime users.

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No.  The OFAC Director, in consultation with the Department of State, has issued a determination pursuant to E.O. 14014 that authorizes the imposition of economic sanctions on any foreign person determined to operate in the jet fuel sector of the Burmese economy.

A sector determination pursuant to E.O. 14014 exposes persons that operate in an identified sector to sanctions risk; however, a sector determination does not automatically impose sanctions on all persons who operate in the sector.  Only foreign persons determined, pursuant to E.O. 14014, by the Secretary of the Treasury in consultation with the Secretary of State, to operate in the jet fuel sector of the Burmese economy are subject to sanctions.

Persons determined to operate in the jet fuel sector of the Burmese economy will be added to the Specially Designated Nationals and Blocked Persons List (SDN List).  

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No.  OFAC has not designated LetterOne and, based on information available to OFAC, LetterOne is not owned 50 percent or more by blocked persons or otherwise considered the blocked property or interest in property of blocked persons, including Petr Olegovich Aven, Mikhail Maratovich Fridman, German Borisovich Khan, and Alexey Viktorovich Kuzmichev.  

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On May 19, 2023, the Department of State designated Russia-based Polimetall AO pursuant to Executive Order (E.O.) 14024.  These blocking sanctions apply only to this entity and any entities in which it owns, directly or indirectly, a 50 percent or greater interest.  

Neither the Department of State nor OFAC have designated this entity’s ultimate parent company, Jersey-based Polymetal International PLC, and based on information available to OFAC, Polymetal International PLC is not owned 50 percent or more by blocked persons or otherwise considered the blocked property of any blocked persons.  U.S. persons, therefore, are not prohibited from dealing with Polymetal International PLC, its non-blocked subsidiaries, or non-blocked affiliates to the extent the proposed dealings do not involve any blocked person, any interest in property of a blocked person, or any other activities prohibited pursuant to any OFAC sanctions authorities.
 

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Section 1(a)(ii) of E.O. 14071 prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any category of services as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, to any person located in the Russian Federation. As of April 12, 2024, categories of services identified pursuant to E.O. 14071 include:

Categories of ServicesDate of DeterminationDate of EffectivenessDefinitions

Accounting;

Trust and corporate formation services;

Management consulting

May 8, 2022June 7, 2022FAQ 1034
Quantum computing September 15, 2022October 15, 2022FAQ 1084
Trading/commodities brokering, financing, shipping, insurance including reinsurance and protection and indemnity, flagging, and customs brokering services as they relate to the maritime transport of crude oil of Russian Federation originDecember 5, 2022December 5, 2022OFAC Guidance on Implementation of the Price Cap Policy
Trading/commodities brokering, financing, shipping, insurance including reinsurance and protection and indemnity, flagging, and customs brokering services as they relate to the maritime transport of petroleum products of Russian Federation originFebruary 5, 2023February 5, 2023OFAC Guidance on Implementation of the Price Cap Policy

Architecture;

Engineering

May 19, 2023June 18, 2023See below
Covered metals acquisition servicesApril 12, 2024April 13, 2024See below
Information Technology (IT)  consultancy and design servicesJune 12, 2024September 12, 2024FAQ 1187
Cloud-based services for enterprise management software and design and manufacturing softwareJune 12, 2024September 12, 2024FAQ 1187
IT support services for enterprise management software and design and manufacturing softwareJune 12, 2024September 12, 2024FAQ 1187

OFAC expects to promulgate regulations that define the terms architecture services, engineering services, and covered metals acquisition services consistent with the following:

Architecture services include advisory services; pre-design services; design services, including schematic design, design development, and final design; contract administration services; combined architectural design and contract administration services; including post construction services; and all other services requiring the expertise of architects.  The prohibition applies to such services as they relate to residential, institutional, leisure, commercial, and industrial buildings and structures; recreational areas; transportation infrastructure; land subdivisions; and not necessarily related to a new construction project.  The term also includes urban planning services (i.e., land use, site selection, and servicing of land for systemic, coordinated urban development) and landscape architectural services.  OFAC intends to interpret this term consistent with UN Central Product Classification (CPC) Codes 86711-86704, 86719, and 86741-86742.

Engineering services include assistance, advisory, consultative, design, and recommendation services concerning engineering matters or during any phase of an engineering project.  Engineering design services may be for:  the construction of foundations and building structures (i.e., structural engineering); mechanical and electrical installations for buildings; the construction of civil engineering works; industrial processes and production; or other engineering designs, such as those for acoustics, vibration, traffic control systems, or prototype development for new products.  The term additionally includes geotechnical, groundwater, and corrosion engineering services; integrated engineering services, such as those for transportation infrastructure or other projects; engineering-related scientific and technical consulting services, including geological, geophysical, geochemical, surface or subsurface surveying, and map making services; testing and analysis services of chemical, biological, and physical properties of materials or of integrated mechanical and electrical systems; and technical inspection services.  OFAC intends to interpret this term consistent with UN CPC Codes 86721-86727, 86729, 86731-86733, 86739, 86751-86754, 86761-86764, and 86769. Additionally, OFAC does not consider maritime classification services to be subject to the prohibition, as is consistent with the OFAC Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin.

Covered metals acquisition services means warranting services for aluminum, copper, or nickel of Russian Federation origin on a global metal exchange and services to acquire aluminum, copper, or nickel of Russian Federation origin as part of the physical settlement of a derivative contract.  “Warranting services” refers to issuing, registering, accepting, or acquiring a warrant or the underlying metal on a global metal exchange (i.e., a commodities exchange that provides infrastructure and services for the international trading of base metal derivatives contracts).  Examples of such global metal exchanges include, but are not limited to, the Chicago Mercantile Exchange, the London Metal Exchange, and the Shanghai Futures Exchange.  “Warrant” means an electronic record or physical document of title to, possession of, or rights in respect of a specified lot of metal (including where such metal is held in a third country within a global metal exchange-approved warehouse). A warrant is created or issued in accordance with the rules of a global metal exchange. 

Updated: June 12, 2024

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A sector determination pursuant to E.O. 14024 exposes persons that operate or have operated in an identified sector to sanctions risk; however, a sector determination does not automatically impose sanctions on all persons who operate or have operated in the sector.  Only persons determined, pursuant to E.O. 14024, by the Secretary of the Treasury in consultation with the Secretary of State, or by the Secretary of State in consultation with the Secretary of the Treasury, or their delegates, to operate or have operated in the above-identified sectors are subject to sanctions.  See FAQ 1126 for the sectors identified pursuant to E.O. 14024 as of May 19, 2023. 

Persons sanctioned pursuant to E.O. 14024 for operating or having operated in an identified sector are added to one or more OFAC sanctions lists based on the type of sanction, including the List of Specially Designated Nationals and Blocked Persons (SDN List), the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List), and the Non-SDN Menu-Based Sanctions List (NS-MBS List).
 

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Section 1(a)(i) of E.O. 14024 imposes sanctions with respect to any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, to operate or have operated in the technology sector or the defense and related materiel sector of the Russian Federation economy, or any other sector of the Russian Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State.  As of May 19, 2023, persons may be sanctioned pursuant to E.O. 14024 for operating or having operated in the following sectors of the Russian Federation economy:

Sector of the Russian Federation EconomyDate of Determination and EffectivenessDefinitions
technologyApril 15, 2021 
defense and related materiel
financial servicesFebruary 22, 2022 
aerospaceMarch 31, 2022 
electronics
marine
accountingMay 8, 2022FAQ 1038
trust and corporate formation services
management consulting
quantum computingSeptember 15, 2022FAQ 1086
metals and miningFebruary 24, 2023FAQ 1115
architectureMay 19, 2023see below
engineering
construction
manufacturing
transportation

OFAC expects to promulgate regulations that define the terms (i) architecture sector of the Russian Federation economy, (ii) engineering sector of the Russian Federation economy, (iii) construction sector of the Russian Federation economy, (iv) manufacturing sector of the Russian Federation economy, and (v) transportation sector of the Russian Federation economy consistent with the following:

Architecture sector of the Russian Federation economy:  The term architecture sector of the Russian Federation economy includes activities such as advising; pre-designing; designing; preparing sketches, reports, studies, assessments, site plans, working drawings, specifications, cost estimates, as-built drawings, or other materials; contract administration; site selection; and inspections concerning architectural and related matters involving the Russian Federation.  Such activities may be related to the following types of projects, e.g.: residential, institutional, leisure, commercial, and industrial buildings and structures; recreational areas; transportation infrastructure; land subdivisions; urban planning; landscape architecture; and not necessarily relate to a new construction project.  The term additionally includes any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the architecture sector of the Russian Federation economy.

Engineering sector of the Russian Federation economy:  The term engineering sector of the Russian Federation economy includes activities such as advising; designing; recommending; consulting; constructing; installing, surveying; preparing studies, specifications, cost estimates, working drawings, process flow diagrams, arrangement drawings, or other materials; map making; planning; testing; analysis; and inspecting for engineering and related matters involving the Russian Federation.  Such activities may be undertaken during any phase of an engineering project of any type and may not necessarily relate to a new construction or development project.  The term additionally includes any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the engineering sector of the Russian Federation economy.

Construction sector of the Russian Federation economy:  The term construction sector of the Russian Federation economy includes activities such as the production, procurement, devising, framing, design, testing, financing, distribution, or transport involving the Russian Federation, of goods, services, or technology to fabricate, shape, alter, maintain, or form any buildings or structures, including the on-site development, assembly, or construction of residential, commercial, or institutional buildings, or of transportation infrastructure, in the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the construction sector of the Russian Federation economy.

Manufacturing sector of the Russian Federation economy:  The term manufacturing sector of the Russian Federation economy includes activities such as the creation, modification, repair, testing, or financing, of goods by manual labor or machinery involving the Russian Federation and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the manufacturing sector of the Russian Federation economy.  Note that persons conducting or facilitating transactions that are exempt or authorized by OFAC—such as those related to the provision of agricultural commodities, food, medicine, or medical devices, or related to energy—will not be subject to sanctions under E.O. 14024.

Transportation sector of the Russian Federation economy:  The term transportation sector of the Russian Federation economy includes activities such as the production, manufacturing, testing, financing, distribution or transport to, from, or involving the Russian Federation of any mode of transport or any goods, services, or technology for the movement or conveyance of persons or property and the loading, unloading, or storage incidental to the movement of such persons or property; and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the transportation sector of the Russian Federation economy.

Technology sector of the Russian Federation economy:  The term technology sector of the Russian Federation economy includes activities such as the production, procurement, research, development, design, engineering, testing, servicing, financing, distribution, use, or transport involving the Russian Federation, of software, equipment, electronics, items, tools, materials, or devices, and any components, parts, or accessories of the foregoing, related to the fields of computing, engineering, applied mathematics, or applied sciences involving the Russian Federation and any related activities, including the provision or receipt of goods or services involving the technology sector of the Russian Federation economy.

Defense and related material sector of the Russian Federation economy:  The term defense and related materiel sector of the Russian Federation economy includes military, armed forces, or security forces  of or within the Russian Federation; the use of arms or related materiel by military, armed forces, or security forces of or within the Russian Federation; any person designing, developing, manufacturing, supplying, financing, procuring, or distributing goods, services, or technology to, from, or involving military, armed forces, or security forces of or within the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology involving the defense and related materiel sector of the Russian Federation economy.  The term defense and related materiel sector of the Russian Federation economy also includes acquisition, possession, procurement, research, design, development, testing, evaluation, manufacture, maintenance, upgrade or refurbishment, shipping, supply, sale, transfer, or storage to, from, within, for, transiting, or on behalf of the Russian Federation of arms or related materiel of all types; enablers, aggregates, components, parts, as well as related documentation and instructions for any such arms or related materiel; or training for the use of included systems, provision of simulation equipment, documentation (including training manuals, maintenance orders, or technical bulletins), prototypes, software upgrades, and licensing and manufacturing agreements for such items.

Aerospace sector of the Russian Federation economy:  The term aerospace sector of the Russian Federation economy includes activities such as the production, procurement, development, design, testing, servicing, financing, distribution, use, or transport involving the Russian Federation and its airspace, of aircraft or any other device used or intended to be used for flight or activities in the air or in space,  missiles, unmanned aerial vehicles, space-based vehicles, satellites, high-altitude balloons, any other device that operates above the surface of the earth, and any items, components, parts, or accessories intended for the foregoing; airports or any other area of land or water used or intended to be used for a purpose related to the aerospace sector of the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology involving the aerospace sector of the Russian Federation economy.

Date Updated: December 22, 2023

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Venezuela General License (GL) 42 generally authorizes transactions prohibited by the Venezuela Sanctions Regulations, 31 CFR part 591 (VSR), that are ordinarily incident and necessary to the negotiation of settlement agreements with the IV National Assembly, its Delegated Commission, an IV National Assembly Entity, or a person appointed or designated by, or whose appointment or designation is retained by, an IV National Assembly Entity relating to any debt of the Government of Venezuela, PdVSA, or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (a "PdVSA Subsidiary").

For the purposes of GL 42, the term “IV National Assembly” means the IV Venezuelan National Assembly seated on January 5, 2016; GL 42 does not authorize transactions involving the Venezuelan National Constituent Assembly convened by Nicolas Maduro or the National Assembly seated on January 5, 2021.  The term “IV National Assembly Entity” includes any entity established by, or under the direction of, the IV National Assembly to exercise its mandate, including persons appointed or designated by, or whose appointment or designation is retained by, an IV National Assembly Entity to the board of directors (including any ad hoc boards of directors), or as an executive officer of a Government of Venezuela entity (including entities owned or controlled, directly or indirectly, by the Government of Venezuela).  Settlement agreements relating to debt include settlement agreements relating to bonds, promissory notes, and other receivables of the Government of Venezuela, PdVSA, or a PdVSA Subsidiary.

GL 42 does not authorize the entry into settlement agreements, contingent or otherwise.  Parties that have negotiated a settlement agreement pursuant to GL 42 will need seek a specific license for entry into that agreement.  OFAC intends to implement a favorable licensing policy for license applications in connection with the negotiation of a settlement agreement, but as with all OFAC licenses and statements of licensing policy, specific licenses will only be granted after due diligence as to the parties and transaction, and this licensing policy would be without prejudice to reconsideration if U.S. foreign policy and national security interests materially change and may be revoked or modified at any time.  GL 42 also does not authorize any transactions, including negotiation of settlement agreements, with persons blocked pursuant to the VSR other than those blocked persons enumerated in GL 42, unless separately authorized.
 

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OFAC will not take enforcement action against any person for taking steps to preserve the ability to enforce bondholder rights to the CITGO shares serving as collateral for the PdVSA 2020 8.5 percent bond (see also OFAC Frequently Asked Question (FAQ) 1123; General License 42 and OFAC FAQ 1125).  This non-enforcement policy governs OFAC sanctions only and does not relieve persons of obligations to comply with any other applicable regulatory requirements, reviews, or approvals that may be necessary to finalize any sale.  As noted in FAQ 1125, parties that have negotiated a settlement agreement pursuant to General License 42 will still need to seek a specific license for entry into that agreement.  

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OFAC will not take enforcement action against any individuals or entities for participating in, facilitating, or complying with the prefatory steps set out in the court’s Sale Procedures Order, or for engaging in transactions that are ordinarily incident and necessary to participating in, facilitating, or complying with such steps (such as serving as potential or actual credit counterparties).  See also General License 42 and OFAC Frequently Asked Question (FAQ) 1125.  As recognized by the judge in the Crystallex case, an additional license will be required before any sale is executed.  As is standard for OFAC’s process before providing a license for the disposition of blocked property, the United States Government will engage in due diligence about the identity of a potential purchaser and will consider relevant details of the proposed transaction.  Before a potential purchaser has been identified, it would be premature to issue any such license or express a definitive view on the issuance of a specific license in a future scenario.  OFAC nevertheless intends to implement a favorable licensing policy toward such license applications in connection with the execution of a sale as contemplated in the Sale Procedures Order.  As with all OFAC licenses and statements of licensing policy, this licensing policy would be without prejudice to reconsideration if U.S. foreign policy and national security interests materially change.  In making these licensing determinations, OFAC is committed to fair and equivalent treatment of potential creditors.

This non-enforcement posture applies to OFAC sanctions only and does not relieve persons of obligations to comply with any other applicable regulatory requirements, reviews, or approvals that may be necessary to finalize any sale.  
 

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The United States generally supports the free flow of information globally as facilitated by telecommunications and certain internet-based communications.  Accordingly, GL 25D authorizes — with certain exceptions and exclusions — (i) all transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR); (ii) the exportation or reexportation, sale, or supply from the United States or by U.S. persons, wherever located, to the Russian Federation of services that are incident to the exchange of communications over the internet and that are prohibited by the RuHSR; and (iii) the exportation or reexportation, sale, or supply from the United States or by U.S. persons, wherever located, to the Russian Federation of software, hardware, or technology incident to the exchange of communications over the internet that is authorized for export to Russia by the Department of Commerce if it is subject to the Export Administration Regulations, 15 CFR parts 730-774 (EAR), or that would be eligible for a license exception or otherwise authorized for export to Russia by the Department of Commerce if it were subject to the EAR (see FAQ 1040). 

However, certain transactions related to Megafon PAO (Megafon) or Limited Liability Company Digital Invest (Digital Invest) — which were designated by the Department of State on April 12, 2023 pursuant to Executive Order 14024 — or any entity in which Megafon or Digital Invest owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively, “Covered Entities”), may not involve the Russian Federation, and thus, may not be authorized by GL 25D.  To ensure certain transactions related to telecommunications and internet-based communications involving the Covered Entities and Tajikistan or Uzbekistan can continue, OFAC issued GL 65.  GL 65 authorizes — with certain exceptions and exclusions — (i) all transactions prohibited by the RuHSR that are ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Covered Entities, and involving Tajikistan or Uzbekistan or (ii) the exportation or reexportation, sale, or supply, directly or indirectly, from the United States or by U.S. persons, wherever located, to the Covered Entities of services, software, hardware, or technology incident to the exchange of communications over the internet that is prohibited by the RuHSR.  Please note that GL 65 does not relieve persons from compliance with other Federal laws, such as the export licensing requirements maintained by the Department of Commerce’s Bureau of Industry and Security.

Updated: June 12, 2024

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Global Magnitsky General License 7 authorizes certain transactions involving the blocked entities Tabacos USA Inc. (Tabacos) and Tabacalera del Este S.A. (Tabesa) (or any entity in which Tabesa or Tabacos owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest) that are ordinarily incident and necessary to payments under the Master Settlement Agreement (MSA) entered into on November 23, 1998 between certain U.S. state and territory attorneys general and certain tobacco companies.  On January 26, 2023, OFAC designated former Paraguayan president Horacio Manuel Cartes Jara (Cartes) pursuant to Executive Order 13818 for involvement in corruption and also designated Tabacos for being owned or controlled by Cartes.  On March 31, 2023, OFAC identified Tabesa as an entity that is owned, directly or indirectly, 50 percent or more by Cartes and added Tabesa to the SDN List.  

Global Magnitsky General License 7 does not authorize debits to any blocked account on the books of a U.S. financial institution or any other transactions otherwise prohibited by the Global Magnitsky Sanctions Regulations.

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Russia-related GL 6C (“Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials”) remains valid and authorizes, among other things, certain transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, ordinarily incident and necessary to (1) the production, manufacturing, sale, transport, or provision  of agricultural commodities, including products such as fish, seafood, or preparations thereof — to the extent they fall within the definition of agricultural commodities provided in GL 6C — to, from, or transiting the Russian Federation (see FAQ 979).  

However, GL 6C does not authorize any transactions prohibited by E.O. 14068, including transactions prohibited by the determination of December 22, 2023 (Seafood Determination).  In particular, E.O. 14068 prohibits the importation into the United States of, among other things, Russian Federation origin fish, seafood, and preparations thereof.  The Seafood Determination further prohibits the importation of salmon, cod, pollock, or crab produced wholly or in part in the Russian Federation, or harvested in waters under the jurisdiction of the Russian Federation or by Russia-flagged vessels, notwithstanding whether such salmon, cod, pollock, or crab has been incorporated or substantially transformed into another product outside of the Russian Federation.   As such, U.S. persons cannot rely on GL 6C for transactions that are for the importation into the United States of Russian Federation origin fish, seafood, or preparations thereof, or salmon, cod, pollock, or crab covered by the Seafood Determination, unless otherwise authorized by OFAC.  However, U.S. persons may continue to rely on GL 6C for transactions otherwise prohibited by E.O. 14024 involving agricultural commodities.

Date Updated: February 23, 2024

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No.  Non-U.S. persons generally do not risk exposure to sanctions for engaging in activities or facilitating transactions for such activities that would be authorized for U.S. persons pursuant to GL O .  Non-U.S. persons unable to wind down transactions in accordance with Iran GL O before 12:01 a.m. eastern daylight time, June 30, 2023, are encouraged to seek guidance from OFAC in advance of that date.

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Iran GL Oauthorizes U.S. persons to wind down all transactions otherwise prohibited by section 5 of Executive Order 13846 involving any vessel blocked as part of the March 2, 2023 designation (“blocked vessels”), subject to certain conditions.  This includes, among other activities, the unloading of any non-Iranian merchandise loaded on the blocked vessel as of March 2, 2023, provided there is no other sanctions nexus.  

U.S. persons are separately prohibited, pursuant to the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), from engaging in most Iran-related transactions.  Accordingly, for blocked vessels containing Iranian-origin merchandise or involving persons ordinarily resident in Iran, Iran GL O provides a separate, more limited authorization under the ITSR.  This narrower authorization under the ITSR allows only transactions ordinarily incident and necessary to certain limited safety and environmental situations:  the safe docking and anchoring of any of the blocked vessels in port; the preservation of the health and safety of the crew; or emergency repairs or environmental mitigation or protection activities.  The offloading of Iranian-origin petroleum, petroleum products, or petrochemical products, regardless of the situation, is not authorized pursuant to Iran GL O and requires a specific license from OFAC.

U.S. financial institutions may also process transactions conducted by non-U.S. persons if such transactions would be authorized for U.S. persons pursuant to Iran GL O.  

Iran GL O is in effect until 12:01 eastern daylight time, June 30, 2023.  Persons unable to complete authorized transactions involving the blocked vessels specified in Iran GL O before its expiration are encouraged to seek guidance from OFAC in advance of that date.  As with all OFAC GLs, Iran GL O only authorizes against the authorities identified in the GL and contains certain conditions.  Please see Iran GL O for further details.

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The Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive), prohibits the following activities by U.S. persons:  any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities (collectively, “Directive 4 entities”).  As noted in FAQ 1002, this includes both direct and indirect transactions.

OFAC issued the Russia-related Sovereign Transactions Directive with the explicit aim of preventing the Government of the Russian Federation from leveraging these institutions and their holdings of international reserves in ways that would undermine the impact of U.S. sanctions.  Information currently available to OFAC suggests so-called “exit taxes” imposed by the Government of the Russian Federation involve payments to Directive 4 entities.  Consequently, U.S. persons whose divestment from the Russian Federation will involve the payment of such an exit tax require a specific license from OFAC prior to the payment of such tax, unless otherwise authorized by OFAC.

GL 13E authorizes U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications involving Directive 4 entities that would otherwise be prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation.  Payment of exit taxes is not considered ordinarily incident and necessary to day-to-day operations in the Russian Federation and, thus, is not authorized under GL 13E. 

Therefore, U.S. persons whose divestment of assets in the Russian Federation will involve a payment of such an “exit tax” should seek a specific license from OFAC.  Such persons may submit a request for a specific license with OFAC’s Licensing Division online at https://ofac.treasury.gov/ofac-license-application-page.  License applications related to these payments should include information regarding the amount of the exit tax, the amount of ongoing taxes that would otherwise be paid to the Government of the Russian Federation should divestment not occur, the impact of a failure to pay the tax on the employees of the exiting company, the specific economic activity in Russia of the exiting company, and the impact on the Russian Federation of the divestment.  OFAC will expedite its review of such requests, which will be evaluated on a case-by-case basis.  

While OFAC is aware that the Commission established by the Russian Federation to review such divestments may include individuals from entities subject to the Russia-related Sovereign Transactions Directive or individuals listed on the Specially Designated Nationals and Blocked Persons List, U.S. persons do not need to seek authorization from OFAC for their Russian buyers to submit an application to the Commission regarding a divestment transaction.
 

Date Updated: May 19, 2023

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The determination made on February 24, 2023 pursuant to Executive Order (E.O.) 14024 authorizes sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy.  Non-U.S. persons may also be exposed to sanctions for activities with persons blocked pursuant to E.O. 14024 (see FAQ 980), including persons blocked following a determination that such persons operate or have operated in the metals and mining sector.

However, OFAC does not intend to target persons for operating in the metals and mining sector where the provision of goods or services is solely for the safety and care of personnel, protection of human life, prevention of accidents or injuries, maintenance or repair necessary to avoid environmental or other significant damage, or activities related to environmental mitigation or remediation.  Examples of such goods include personal protective equipment, safety devices, ventilation systems, and alarm systems; examples of such services include rescue and accident response services, cleaning, safety inspections, and services necessary for use of the goods described above.

In addition, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under E.O. 14024 for engaging in transactions with blocked persons, including in the metals and mining sector, where those transactions would not require a specific license if engaged in by a U.S. person.  For example, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions for engaging in transactions in the metals and mining sector if such transactions would be authorized for U.S. persons by General License (GL) 8F (authorizing certain energy-related transactions) or by GL 6C  (authorizing certain transactions related to the production, manufacturing, sale, transport, or provision of medicine or medical devices, including certain industrial isotopes used in nuclear medicine, among other things). 

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No.  The Director of OFAC, in consultation with the State Department, has issued a determination pursuant to E.O. 14024  that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy.  

A sector determination pursuant to E.O. 14024  exposes persons that operate or have operated in an identified sector to sanctions risk; however, a sector determination does not automatically impose sanctions on all persons who operate or have operated in the sector.  Only persons determined pursuant to E.O. 14024 to operate or have operated in the above-identified sector are subject to sanctions.

Certain additional sanctions may apply to dealings in the metals and mining sector of the Russian Federation economy.  For example, E.O. 14071 prohibits U.S. persons from new investment in the Russian Federation, including in the metals and mining sector.  In addition, certain goods produced by the metals and mining sector of the Russian Federation economy may be prohibited from importation into the United States pursuant to E.O. 14068, such as non-industrial diamonds and gold of Russian Federation origin.  For more information about prohibitions related to non-industrial diamonds, see Frequently Asked Questions (FAQs) 1022, 1023, 1024, 1026, and 1027 .  For more information about prohibitions related to gold, see FAQs 1029 and 1070 .

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For the purposes of the determination of February 24, 2023 made pursuant to E.O. 14024, OFAC anticipates publishing regulations defining the term “metals and mining sector of the Russian Federation economy” to include any act, process, or industry of extracting, at the surface or underground, ores, coal, precious stones, or any other minerals or geological materials in the Russian Federation, or any act of procuring, processing, manufacturing, or refining such geological materials, or transporting them to, from, or within the Russian Federation.  This is the definition OFAC used to define the same term in the Ukraine/Russia-related Sanctions Regulations (see 31 CFR 589.325).

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On February 24, 2023, the Director of OFAC, in consultation with the Department of State, issued a sectoral determination pursuant to Executive Order (E.O.) 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy.  This sectoral determination is effective February 24, 2023.  Also on February 24, 2023, OFAC designated certain entities for operating in the metals and mining sector of the Russian Federation economy.  The U.S. government may, as appropriate, impose sanctions on additional persons determined pursuant to E.O. 14024 to operate or to have operated in this sector.  For further information, please see FAQ 1115

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No.  U.S. persons, including U.S. financial institutions, may transfer securities issued by non-blocked Russian entities from a decedent’s estate to the account of a relevant beneficiary or beneficiaries, including a successor entity (e.g., a family trust), provided such transfers (i) are part of the ordinary course administration of the decedent’s estate, (ii) do not involve an exchange for value, and (iii) have no other sanctions nexus (including the involvement of blocked persons).  

Please note, however, that blocked securities in a decedent’s estate must remain blocked.  The administration of a decedent’s estate requiring the transfer of blocked securities would require a specific license from OFAC.  To apply for a specific license, please go to our License Application Page.  

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On January 26, 2023, OFAC designated, pursuant to E.O. 13818, Horacio Manuel Cartes Jara (Cartes) for his involvement in corruption in Paraguay.  Also on that day, OFAC designated four entities owned or controlled by Cartes, pursuant to E.O. 13818:  Tabacos USA Inc., Bebidas USA Inc., Dominicana Acquisition S.A., and Frigorifico Chajha S.A.E. (collectively, “designated Cartes entities”).  Concurrent with this action, OFAC issued Global Magnitsky General License (GL) 6 , which authorizes, subject to certain conditions, transactions prohibited by the Global Magnitsky Sanctions Regulations, 31 CFR part 583 (GMSR), that are ordinarily incident and necessary to the wind down of any transaction involving any of the designated Cartes entities, or any entity in which Cartes or the designated Cartes entities own, directly or indirectly, a 50 percent or greater interest (collectively, “blocked Cartes entities”), through 12:01 a.m. eastern daylight time, March 27, 2023, provided that any payment to a blocked person must be made into a blocked account in accordance with the GMSR.  GL 6 does not authorize any transactions involving Cartes himself.

After the expiration of this general authorization, U.S. persons will be prohibited from engaging in such wind-down transactions with blocked Cartes entities, unless exempt or otherwise authorized by OFAC.  U.S. persons unable to wind down transactions with blocked Cartes entities before 12:01 a.m. eastern daylight time, March 27, 2023, are encouraged to seek guidance from OFAC.

Non-U.S. persons may wind down transactions with blocked Cartes entities without exposure to sanctions under E.O. 13818, provided that such wind-down activity is consistent with GL 6.  Wind-down transactions involving non-U.S. persons may be processed through the U.S. financial system or involve U.S. persons as long as the transactions comply with the terms and conditions in GL 6.  Non-U.S. persons unable to wind down transactions with blocked Cartes entities before 12:01 a.m. eastern daylight time, March 27, 2023, are encouraged to seek guidance from OFAC.

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On January 26, 2023, OFAC designated Frigorifico Chajha S.A.E. (Frigorifico Chajha), pursuant to E.O. 13818.  Concurrent with this action, OFAC issued General License (GL) 5 , which authorizes certain transactions ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity of Frigorifico Chajha to a non-U.S. person, through 12:01 a.m. eastern daylight time, March 27, 2023.  

GL 5 also authorizes certain transactions ordinarily incident and necessary to facilitating, clearing, and settling trades of debt or equity of Frigorifico Chajha that were placed prior to 4:00 p.m. eastern standard time, January 26, 2023, through 12:01 a.m. eastern daylight time, March 27, 2023.  

GL 5 also authorizes certain transactions that are ordinarily incident and necessary to the wind down of derivative contracts entered into prior to 4:00 p.m. eastern standard time, January 26, 2023, that (1) include Frigorifico Chajha as a counterparty, or (2) are linked to the debt or equity of Frigorifico Chajha, through 12:01 a.m. eastern daylight time, March 27, 2023, provided that any payments to a blocked person are made into a blocked account in accordance with the Global Magnitsky Sanctions Regulations, 31 CFR part 583.  

However, GL 5 does not authorize U.S. persons to sell, or to facilitate the sale of, debt or equity of Frigorifico Chajha to, directly or indirectly, any person whose property and interests in property are blocked.  GL 5 also does not authorize U.S. persons to purchase or invest in, or to facilitate the purchase of or investment in, directly or indirectly, debt or equity of Frigorifico Chajha, other than purchases of or investments in debt or equity of Frigorifico Chajha that are ordinarily incident and necessary to the divestment or transfer of debt or equity of Frigorifico Chajha as described in GL 5.

Non-U.S. persons generally do not risk exposure to U.S. sanctions for engaging in activities that would be exempt or authorized for U.S. persons pursuant to GL 5. 

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On May 17, 2024, OFAC amended 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) to incorporate the provisions of General License (GL) D-2 into 31 CFR § 560.540, with certain additional amendments.  Section 560.540 supersedes GL D-2, which OFAC issued on September 23, 2022, to further support the provision of communication tools to ordinary Iranians and assist in their efforts to resist repressive internet censorship and surveillance tools deployed by the Iranian government.  In addition to incorporating GL D-2 into the ITSR, the amended 31 CFR § 560.540 includes several key changes: 

  • The list of services, software, and hardware incident to communications authorized for exportation, reexportation, or provision to Iran previously found in the Annex to GL D-2 is now found in the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications.
  • Effective [30 DAYS AFTER PUBLICATION] OFAC is amending the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications to exclude laptops, tablets, and personal computing devices with an “Adjusted Peak Performance” (“APP”) exceeding 1 Weighted TeraFLOP (WT). 
  • The authorization previously found at paragraph (a)(5) of GL D-2 and now incorporated into 31 CFR § 560.540(a)(5) is revised to authorize transactions for the importation of hardware or software into third countries, in addition to the United States, provided that the items were previously exported to Iran pursuant to an authorization issued pursuant to the ITSR.
  • OFAC has added a new 31 CFR § 560.540(a)(7) to authorize the exportation or reexportation of certain services conducted outside Iran to install, repair, or replace hardware or software authorized for exportation, reexportation, or provision to Iran by paragraphs (a)(2) or (3).  The new 31 CFR § 560.540(a)(7) authorizes such services only when the service provider is located outside Iran and does not authorize the service provider to engage in such services while in Iran.
  • Section 560.540(b)(3), which incorporates paragraph (b) of GL D-2, is also being revised to clarify the restrictions related to provision of web-hosting services or of domain name registration services in Iran authorized by 31 CFR § 560.540(a) by specifically excluding from authorization the exportation or reexportation of web-hosting services for websites of commercial entities located in Iran or of domain name registration services for or on behalf of the Government of Iran or another person whose property and interests in property are blocked pursuant to Section 560.211 of the ITSR.
  • Section 560.540(d) has been added to set forth the case-by-case licensing policy previously set forth in paragraph (d) of GL D-2, for additional activities that support internet freedom in Iran, such as development and hosting of anti-surveillance software by Iranian developers Such services would also include, for example, the development and hosting of anti-censoring software by Iranian software developers and the exportation of certain software development tools to Iranians seeking to create their own anti-surveillance or anti-censorship apps and upload them to mobile app sites. 

Date Updated: May 16, 2024

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No, provided the petroleum products are unloaded at the port of destination prior to 12:01 a.m., eastern daylight time, April 1, 2023.  Petroleum products of Russian Federation origin that are loaded onto a vessel at the port of loading prior to 12:01 a.m., eastern standard time, February 5, 2023, and unloaded at the port of destination prior to 12:01 a.m., eastern daylight time, April 1, 2023, are not subject to the price cap.  U.S. service providers can continue to provide services related to the maritime transport of petroleum products of Russian Federation origin purchased at a price above the price cap, provided that the petroleum products are loaded onto a vessel at the port of loading for maritime transport prior to 12:01 a.m., eastern standard time, February 5, 2023, and unloaded at the port of destination prior to 12:01 a.m., eastern daylight time, April 1, 2023.

The following is an example of a permissible transaction: 

  • A U.S. commodities trader signs a contract on January 1, 2023, to purchase petroleum products of Russian Federation origin for shipment to a jurisdiction that has not prohibited the import of such petroleum products.  The U.S. commodities trader arranges for the petroleum products to be loaded onto a vessel at the port of loading.  The vessel is loaded on February 1, 2023, and a bill of lading is issued.  The petroleum products are shipped and discharged at the port of destination on February 15, 2023.  U.S. insurance companies provide cover for this shipment/voyage and pay out any related claims, as appropriate.

OFAC anticipates implementing the price cap on petroleum products of Russian Federation origin by publishing a determination pursuant to Executive Order 14071 that (i) permits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of services related to the maritime transport of petroleum products of Russian Federation origin, where the price of such petroleum products of Russian Federation origin do not exceed the price cap and (ii) prohibits such services if the petroleum products of Russian Federation origin are purchased above the relevant price cap.  This determination would take effect at 12:01 a.m., eastern standard time, February 5, 2023, with respect to maritime transport of petroleum products of Russian Federation origin loaded on or after 12:01 a.m., eastern standard time, February 5, 2023. 

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No.  OFAC’s action of December 20, 2022 does not restrict the scope of any existing exemptions or OFAC authorizations for humanitarian activities, including existing general licenses authorizing certain NGO activities in sanctioned jurisdictions such as the Crimea Region of Ukraine, Iran, and Syria, which have not been amended by this action, and pre-existing web general licenses that have been incorporated into the relevant program regulations, such as Venezuela GL 20B.  Persons conducting humanitarian activities pursuant to these programs may continue to rely on existing exemptions and OFAC authorizations, subject to the applicable conditions and limitations, which may differ by sanctions program.

For information on specific exemptions or authorizations under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and OFAC’s Sanctions Programs and Country Information page.  
 

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For an organizational chart of the United Nations (UN), which lists the UN Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations, including the World Bank, please see this page on the UN website.  The IO GLs also authorize the activities of the fund entities administered or established by the foregoing UN organizations, as well as the activities of the international organizations and entities themselves, in addition to the activities of their employees, contractors, and grantees.

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U.S. financial institutions may operate accounts, including processing funds transfers, for persons engaging in activities authorized by the GLs related to: (i) the official business of the U.S. government, (ii) official business of certain international organizations and entities, (iii) certain humanitarian and other specified activities by nongovernmental organizations (NGOs), and (iv) the provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices for personal, non-commercial use.  In assessing whether a particular transaction is in compliance with such GLs, financial institutions may reasonably rely upon the information available to them in the ordinary course of business, provided that the financial institution does not know or have reason to know that the transaction is outside the scope of the applicable GL. 

Separately, non-U.S. persons, including NGOs and other entities, as well as foreign financial institutions facilitating or assisting these activities, do not risk exposure to U.S. sanctions for engaging in or facilitating transactions that are otherwise exempt or authorized for U.S. persons pursuant to these GLs.

For general information on OFAC’s due diligence expectations and compliance programs, please see A Framework for OFAC Compliance Commitments and FAQ 819.

If financial institutions have questions about engaging in or processing transactions related to these authorizations, they may contact the OFAC Compliance Hotline by email at OFAC_Feedback@treasury.gov or by phone at (800) 540-6322 or (202) 622-2490.  OFAC prioritizes responding to questions related to humanitarian activity.
 

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On December 9, 2022, the United Nations (UN) Security Council adopted UNSCR 2664, which establishes a humanitarian carveout to the asset freeze measure across United Nations sanctions regimes.  The carveout enables the flow of legitimate humanitarian assistance and activities supporting the basic human needs of vulnerable populations while continuing to deny resources to malicious actors.  On December 20, 2022, OFAC announced the issuance or amendment of four categories of general licenses (GLs) that support the conduct of U.S. government and humanitarian-related activities across a number of sanctions programs, including in OFAC sanctions programs that implement UN sanctions regimes.   

Specifically, across a number of sanctions programs, OFAC issued or amended four categories of GLs authorizing the following activities:

  • the official business of the U.S. government; 
  • the official business of certain international organizations and entities; 
  • transactions incident to certain humanitarian and other activities by nongovernmental organizations; and
  • the provision of food and other agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices for personal, non-commercial use.  

For more information on the sanctions programs covered by these new or amended GLs, please see the Federal Register here and here.  For information on specific exemptions or authorizations under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and OFAC’s Sanctions Programs and Country Information page.  

For humanitarian-related activity that may fall outside the scope of these authorizations, OFAC considers specific license requests on a case-by-case basis and prioritizes license applications and other requests for guidance that are related to humanitarian activity.  Please see OFAC’s License Application Page for additional details regarding the specific licensing process. 

If individuals, nongovernmental organizations, international organizations, or other entities, including financial institutions, have questions about engaging in or processing transactions related to these authorizations, they may contact the OFAC Compliance Hotline by email OFAC_Feedback@treasury.gov or by phone at (800) 540-6322 or (202) 622-2490.  As with specific license requests, OFAC prioritizes responding to questions related to humanitarian activity.
 

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No.  OFAC has not designated Norilsk Nickel and, based on information available to OFAC as of December 15, 2022, Norilsk Nickel is not owned 50% or more by blocked persons or otherwise considered the blocked property of Vladimir Potanin.                                                                                                                                                                                                                                                                                                                                                                                                                              

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OFAC issued General Licenses (GL) 58 and 59 concurrent with the designation of Rosbank.  GL 58 authorizes a wind-down period for transactions involving Rosbank or any entity in which Rosbank owns, directly or indirectly, a 50 percent or greater interest (“Rosbank entities”) until 12:01 a.m. eastern daylight time, March 15, 2023.  This includes transactions ordinarily incident and necessary to exit operations, contracts, or other agreements involving Rosbank entities that were in effect prior to December 15, 2022, provided that such transactions do not involve a debit to a blocked account on the books of a U.S. financial institution (see Frequently Asked Question (FAQ) 990).  Wind-down activities covered by GL 58 do not include the continued processing of funds transfers, securities trades, or other transactions that involve a Rosbank entity that were part of ongoing business activities prior to the imposition of sanctions, unless separately authorized (see, e.g., GLs 6B, 8E, or 59).

In addition, GL 58 authorizes U.S. persons, including U.S. financial institutions, to reject, rather than block, all transactions ordinarily incident and necessary to the processing of funds involving one or more Rosbank entities as an originating, intermediary, or beneficiary financial institution, through 12:01 a.m. eastern daylight time, March 15, 2023.  For individuals holding accounts at Rosbank entities, see FAQ 1080 for guidance, including GL 50, which authorizes individuals to engage in all transactions ordinarily incident and necessary to close their individual accounts held at a financial institution blocked pursuant to E.O. 14024.

GL 59 authorizes U.S. persons to divest or transfer holdings in securities of Rosbank entities to non-U.S. persons, as well as the wind down of certain derivative contracts, subject to certain conditions.  Please see GL 59 for additional details.

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No.  Non-U.S. persons may engage in the transactions authorized for U.S. persons by Global Magnitsky General License (GL) 3 and wind down transactions with the blocked persons specified in GL 4, without exposure to sanctions under Executive Order (E.O.) 13818 or the Global Magnitsky Sanctions Regulations, 31 CFR part 583, provided that such activity is consistent with those GLs.  Further, such transactions involving non-U.S. persons may be processed through the U.S. financial system or involve U.S. persons as long as the transactions comply with the terms and conditions in GLs 3 and 4.  Non-U.S. persons unable to wind down transactions in accordance with GLs 3 and 4 before 12:01 a.m. eastern standard time, March 9, 2023, are encouraged to seek guidance from OFAC before that date.

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On December 9, 2022, OFAC designated, pursuant to Executive Order (E.O.) 13818, several persons, including Dalian Ocean Fishing Co., Ltd.; Fujian Provincial Pingtan County Ocean Fishing Group Co., Ltd.; Fuzhou Honglong Ocean Fishing Co. Ltd.; and Pingtan Marine Enterprise Ltd. Concurrent with this action, OFAC issued Global Magnitsky General License (GL) 4, which authorizes all transactions ordinarily incident and necessary to the wind down of any transaction involving any vessel in which any of these blocked entities have an interest that would otherwise be prohibited by the Global Magnitsky Sanctions Regulations, 31 CFR part 583, through 12:01 a.m. eastern standard time, March 9, 2023, provided that any payment to a blocked person must be made into a blocked account in accordance with OFAC sanctions regulations.

The wind-down authorization in GL 4 contemplates, for example, completion of ongoing voyages, including the discharge of cargo aboard such vessels to non-blocked persons; docking or anchoring of the vessels at third-country, non-sanctioned ports; transactions related to the safety and maintenance of such vessels, such as entering into certain contracts to pay for insurance coverage, flagging, and safety and compliance inspections during the wind-down period; and transactions related to the health and safety of any crew, including the provision and processing of wages or other employee benefits, or other provision of crewing services.

After the expiration of this authorization, persons will be prohibited from engaging in such wind-down transactions with the blocked persons or vessels, unless exempt or otherwise authorized by OFAC.  Persons unable to wind down transactions with the blocked persons or vessels specified in GL 4 before 12:01 a.m. eastern standard time, March 9, 2023, are encouraged to seek guidance from OFAC before that date.  Please see GL 4 for further details.  

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Pursuant to Global Magnitsky General License (GL) 3, U.S. persons are authorized to engage in certain transactions that would otherwise be prohibited by the Global Magnitsky Sanctions Regulations, 31 CFR part 583, ordinarily incident and necessary to the divestment or transfer, or facilitation of the divestment or transfer, of debt or equity of PME to a non-U.S. person through 12:01 a.m. eastern standard time, March 9, 2023.  

GL 3 also authorizes transactions ordinarily incident and necessary to facilitating, clearing, and settling trades of debt or equity of PME that were placed prior to 4:00 p.m. eastern standard time, December 9, 2022, through 12:01 a.m. eastern standard time, March 9, 2023.  

GL 3 also authorizes, through 12:01 a.m. eastern standard time, March 9, 2023, transactions ordinarily incident and necessary to the wind down of financial contracts or other agreements linked to the debt or equity of PME and entered into prior to 4:00 p.m. eastern standard time, December 9, 2022, provided that any payments to a blocked person are made into a blocked account in accordance with OFAC sanctions regulations.  This authorization includes transactions ordinarily incident and necessary to the delisting of PME from a U.S. securities exchange. 

However, GL 3 does not authorize U.S. persons to sell or facilitate the sale of debt or equity of PME to, directly or indirectly, any person whose property and interests in property are blocked, including Xinrong Zhuo, who was designated on the same day and is PME’s chairman and CEO, among other things.  U.S. persons unable to wind down transactions in accordance with GL 3 before 12:01 a.m. eastern standard time, March 9, 2023, are encouraged to seek guidance from OFAC before that date.  Please see GL 3 for further details.  

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No.  Non-U.S. persons, including foreign financial institutions, generally do not risk exposure to U.S. sanctions for facilitating transactions or payments for or on behalf of, directly or indirectly, Chevron, its subsidiaries, joint ventures, or contractors that are authorized pursuant to Venezuela GL 41.  Non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under the Venezuela Sanctions Regulations, 31 CFR Part 591, for engaging in transactions with blocked persons, where those transactions would not require a specific license if engaged in by a U.S. person.  

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Yes, provided that such goods and services are for certain activities related to the operation and management of Chevron’s joint ventures in Venezuela, as specified in GL 41.  Such activities include, among others, the production and lifting of petroleum or petroleum products produced by the Chevron’s JVs; related maintenance, repair, or servicing of the Chevron JVs; sale of petroleum or petroleum products to the United States produced by the Chevron JVs , provided that the petroleum and petroleum products produced by the Chevron JVs are first sold to Chevron; the procurement and import into Venezuela of goods or other inputs for authorized activities; and the processing of payments by U.S. financial institutions related to the foregoing activities.  Please see GL 41 for a complete list of authorized activities and associated conditions.

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GL 21B authorizes all activities otherwise prohibited by the Global Terrorism Sanctions Regulations (GTSR), 31 CFR part 594, that are ordinarily incident and necessary to the limited safety and environmental activities described in paragraph (a) of GL 21B involving certain blocked persons and vessels through 12:01 a.m. eastern daylight time, April 13, 2023.  GL 21B does not authorize the offloading of any cargo onboard any of the blocked vessels listed in GL 21B, and any payment of claims to or for the benefit of any blocked persons or vessels would require a specific license from OFAC.  

After the expiration of GL 21B, U.S. persons will be prohibited from engaging in any transactions with the blocked persons or vessels listed in GL 21B, unless otherwise exempt or authorized by OFAC.  U.S. persons unable to conclude transactions authorized by GL 21B before 12:01 a.m. eastern daylight time, April 13, 2023, are encouraged to seek guidance from OFAC.  

Non-U.S. persons, including foreign financial institutions, generally do not risk exposure to sanctions for engaging in transactions with blocked persons where those transactions would not require a specific license if engaged in by a U.S. person.  Non-U.S. persons unable to conclude transactions authorized by GL 21B before 12:01 a.m. eastern daylight time, April 13, 2023, are encouraged to seek guidance from OFAC.

Date Updated: January 12, 2023

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OFAC issued Russia-related General License (GL) 53 to authorize U.S. persons to engage in all transactions ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation (“Russian missions”), where the transactions are prohibited by Directive 4 under Executive Order (E.O.) 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation.  This authorization applies to transactions related to Russian missions located in or outside the United States.  For example, GL 53 authorizes the payment of salaries to employees of Russian missions that may otherwise be prohibited by Directive 4, such as a payment originated by the Ministry of Finance of the Russian Federation from a non-blocked Russian bank.  Importantly, GL 53 does not authorize any transactions involving blocked persons, including blocked Russian financial institutions; nor does it authorize debits to the accounts on the books of U.S. financial institutions of entities subject to Directive 4.  Non-U.S. persons may engage in transactions that are authorized for U.S. persons under this GL without risk of sanctions under E.O. 14024.

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A “person” subject to designation under E.O. 13722 or E.O. 13694, as amended, includes an individual or an entity, defined as “a partnership, association, trust, joint venture, corporation, group, subgroup, or other organization.”  Once OFAC has determined that a person is subject to sanctions, OFAC adds that person to the Specially Designated Nationals and Blocked Persons List.

OFAC designated the entity known as Tornado Cash, which is a “partnership, association, joint venture, corporation, group, subgroup, or other organization” that may be designated pursuant to IEEPA.  Tornado Cash’s organizational structure consists of: (1) its founders and other associated developers, who together launched the Tornado Cash mixing service, developed new Tornado Cash mixing service features, created the Tornado Cash Decentralized Autonomous Organization (DAO), and actively promoted the platform’s popularity in an attempt to increase its user base; and (2) the Tornado Cash DAO, which is responsible for voting on and implementing new features created by the developers.  Tornado Cash uses computer code known as “smart contracts” to implement its governance structure, provide mixing services, offer financial incentives for users, increase its user base, and facilitate the financial gain of its users and developers.  OFAC has not designated Tornado Cash’s individual founders, developers, members of the DAO, or users, or other persons involved in supporting Tornado Cash at this time.  However, all Tornado Cash property and interests in property are blocked, and U.S. persons cannot transact with Tornado Cash or deal in its property and interests in property, absent authorization from OFAC.  See FAQs 1077 and 1078.

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No, provided the oil is unloaded at the port of destination prior to 12:01 a.m., eastern standard time, January 19, 2023.  Crude oil of Russian Federation origin that is loaded onto a vessel at the port of loading prior to 12:01 a.m., eastern standard time, December 5, 2022, and unloaded at the port of destination prior to 12:01 a.m., eastern standard time, January 19, 2023, is not subject to the price cap (also known as the “maritime services policy”).  U.S. service providers can continue to provide services related to the maritime transport of crude oil of Russian Federation origin purchased at a price above the price cap, provided that the crude oil is loaded onto a vessel at the port of loading for maritime transport prior to 12:01 a.m., eastern standard time, December 5, 2022, and unloaded at the port of destination prior to 12:01 a.m., eastern standard time, January 19, 2023. 


The following is an example of a permissible transaction in line with the maritime services policy:

  • A U.S. commodities trader signs a contract on November 1, 2022, to purchase crude oil of Russian Federation origin for shipment to a jurisdiction that has not prohibited the import of such crude oil.  The U.S. commodities trader arranges for the oil to be loaded onto a vessel at the port of loading.  The vessel is loaded on December 1, 2022, and a bill of lading is issued.  The oil is shipped and discharged at the port of destination on December 15, 2022.  U.S. insurance companies provide cover for this shipment/voyage and pay out any related claims, as appropriate.

 

As noted in OFAC’s preliminary guidance, OFAC anticipates implementing the maritime services policy by publishing a determination pursuant to Executive Order 14071 that (i) permits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of services related to the maritime transport of crude oil or petroleum products of Russian Federation origin, where the price of such crude oil or petroleum products of Russian Federation origin does not exceed the price cap and (ii) prohibits such services if the crude oil or petroleum products of Russian Federation origin are purchased above the price cap.  This determination would take effect at 12:01 a.m., eastern standard time, December 5, 2022, with respect to maritime transport of crude oil of Russian Federation origin loaded on or after 12:01 a.m., eastern standard time, December 5, 2022.

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Nicaragua GL 4  authorizes U.S. persons to engage in transactions prohibited by the Nicaragua Sanctions Regulations, 31 CFR part 582 (the NSR), that are ordinarily incident and necessary to the wind down of any transaction involving the Directorate General of Mines (DGM) of the Nicaraguan Ministry of Energy and Mines, or any entity in which DGM owns, directly or indirectly, a 50 percent or greater interest (collectively, “Blocked DGM Entities”), through 12:01 a.m. eastern standard time, November 23, 2022, provided that any payment to a blocked person must be made into a blocked account in accordance with the NSR.

After the expiration of this authorization, unless exempt or authorized by the Office of Foreign Assets Control, U.S. persons will be prohibited from engaging in transactions with the Blocked DGM Entities and must block property or interests in property of any Blocked DGM Entities that are in, or thereafter come within, the United States, or the possession or control of a U.S. person.

Non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under the NSR for engaging in transactions with blocked persons where those transactions would not require a specific license if engaged in by a U.S. person. 

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Yes.  Multiple Russia-related sanctions authorities authorize sanctions against non-U.S. persons that provide goods, services, or other support for Russia’s military-industrial complex.  For example, OFAC may block any person determined to operate or have operated in the defense and related materiel sector of the Russian Federation economy pursuant to Executive Order (E.O.) 14024 of April 15, 2021, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation.”  In addition, pursuant to E.O. 14024, OFAC may block persons determined to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of certain sanctionable activities enumerated in E.O. 14024 or any person whose property and interests in property are blocked pursuant to E.O. 14024.  OFAC also has robust targeting authorities pursuant to the Ukraine-/Russia-Related Sanctions Regulations (URSR), 31 C.F.R. part 589, which implement multiple authorities that could provide for the blocking of persons who engage in the provision of ammunition or other military goods to the Russian Federation, including persons determined to operate or have operated in the arms or related materiel sector of the Russian Federation economy, or those who have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of persons blocked pursuant to the URSR.  

Furthermore, E.O. 14024, as amended by E.O. 14114, authorizes the imposition of sanctions on foreign financial institutions that have conducted or facilitated certain transactions involving Russia’s military-industrial base.  For more information, see OFAC’s Advisory to Foreign Banks on Russia Sanctions Risks, and FAQs 1147, 1148, 1149, 1150 and 1151.

OFAC is prepared to use its broad targeting authorities against non-U.S. persons that provide ammunition or other support to the Russian Federation’s military-industrial complex, as well as private military companies (PMCs) or paramilitary groups participating in or otherwise supporting the Russian Federation’s unlawful and unjustified attack on Ukraine.  OFAC will continue to target Russia’s efforts to resupply its weapons and sustain its war of aggression against Ukraine, including any foreign persons who assist the Russian Federation in those efforts. 

OFAC and the Department of State have imposed numerous targeted sanctions on the Russian Federation’s military-industrial complex, including on State Corporation Rostec, the cornerstone of Russia’s defense-industrial base, and multiple other key firms.  In addition, the Department of State has identified persons that are part of, or operate for or on behalf of, the defense and intelligence sectors of the Government of the Russian Federation pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) (CAATSA 231 List of Specified Persons).  Persons determined to knowingly engage in a significant transaction with those identified on the CAATSA 231 List of Specified Persons are subject to five or more sanctions described in Section 235 of CAATSA.  The Department of Commerce’s Bureau of Industry and Security (BIS) has also imposed highly restrictive controls on the export and reexport of U.S.-origin and certain foreign-produced commodities, software, and technologies to the Russian Federation to cut off its access to inputs and products needed to sustain its military capabilities.  For more information on the impact of sanctions and export controls on Russia’s military-industrial complex, please see “OFAC-BIS Alert: Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex,” published on October 14, 2022 and BIS’s Common High Priority Items List

Date Updated: February 23, 2024

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Yes.  On September 23, G7 Leaders issued a statement condemning Russia’s sham referenda and noting their collective readiness to impose further economic costs on Russia, and on individuals and entities both inside and outside of Russia that provide political or economic support for Russia’s illegal attempts to change the status of Ukrainian territory.  

The United States is prepared to more aggressively use its authorities under existing U.S. sanctions programs to target such persons whose activities may constitute material assistance, sponsorship, financial, material, or technological support for, or goods or services to, or in support of (together “material support”), sanctioned persons or sanctionable activity.  Particular areas of targeting focus include entities and individuals in jurisdictions outside Russia that provide political or economic support for Russia’s illegal attempt to annex Ukrainian sovereign territory.  Examples of activities that could be targeted include those related to:

  • Providing material support for the organization of Russia’s sham referenda or annexation, as well as economic or other activity that seeks to legitimize Russia’s sham referenda or annexation;
  • Providing material support to Russia’s military and defense industrial base, including significant transactions by entities in third countries that provide material support to Russia’s military, defense industrial base, and designated entities and persons operating in Russia’s defense industrial base;
  • Attempting to circumvent or evade U.S. sanctions on Russia and Belarus; and
  • Providing material support to Russian entities or individuals subject to certain blocking sanctions.

Multiple Executive Orders (E.O.) — including E.O.s 13660, 14024, and 14065 — authorize the imposition of blocking sanctions on categories of persons — inside or outside Russia — who provide material support for Russia following its sham referenda, purported annexation, and continued occupation of the Kherson, Zaporizhzhya, Donetsk, and Luhansk regions of Ukraine. 

U.S. sanctions are not designed to target Ukraine or the Ukrainian people, including those living in areas occupied or purportedly annexed by Russia.  In addition, as noted in OFAC’s Fact Sheet: Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine and Frequently Asked Question (FAQ) 1007, OFAC sanctions do not target transactions related to the export of food or medicine, the response to the Coronavirus Disease 2019 (COVID-19) pandemic, the official business of an international organization, or the activities of nongovernmental organizations, as well as personal remittances, telecommunications, internet services, or mail.  

Finally, OFAC sanctions do not prohibit transactions related to the sale of or transport of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin, aside from the importation of such products into the United States.  OFAC will generally not impose sanctions on non-U.S. persons that engage in transactions that would be authorized for U.S. persons.  For additional information, please see Russia-related General License (GL) 8C, FAQ 980, and FAQ 1018.  OFAC has issued preliminary guidance on the planned maritime services policy and related price exception for seaborne Russian oil and intends to issue additional guidance in coming weeks. 
 

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Yes, provided the underlying remittance transactions are authorized under 31 CFR § 515.570 of the Cuban Assets Control Regulations (CACR) and the digital payment service provider is a U.S.-registered money transmitter or other qualifying banking institution within the definition of that term provided in 31 CFR § 515.314.  For purposes of this FAQ, “digital payments” means transfers of funds sent through mobile money, mobile wallets, digital bank accounts, credit/debit cards, online payments, or other digital technology.

Pursuant to 31 CFR § 515.570 of the CACR, OFAC authorizes persons subject to U.S. jurisdiction to make certain categories of remittances to persons in Cuba, subject to certain conditions (please see FAQ 732 for an overview of the types of remittances U.S. persons can send and applicable conditions and requirements).  Additionally, pursuant to 31 CFR § 515.572(a)(3) of the CACR, banking institutions, as defined in 31 CFR § 515.314, including U.S.-registered money transmitters, are authorized to provide services in connection with the collection, forwarding, or receipt of authorized remittances.  Thus, digital payments service providers that fall within the definition of “banking institution” provided in 31 CFR § 515.314, including U.S.-registered money transmitters, can process authorized remittances to Cuba via digital payments. 

A banking institution is expected to conduct a level of due diligence commensurate with its overall risk profile and internal compliance policies and procedures.  However, as noted in FAQ 1057, banking institutions, including U.S-registered money transmitters within the context of § 515.572(a)(3), may rely on the statements of their customers that remittance transactions are authorized unless they know or have reason to know a transaction is not authorized. 

Section 515.572(a)(3) of the CACR does not authorize any transaction related to the collection, forwarding, or receipt of remittances involving any entity or subentity identified on the State Department’s Cuba Restricted List (CRL).  

Generally, OFAC’s general licenses are self-executing.  This means that if U.S. persons assess that their transactions fall within the scope of the authorizations in 31 CFR § 515.570 and 31 CFR § 515.572, they may execute such transactions without further assurance from OFAC.  
For transactions that do not fall within the scope of these authorizations, U.S. persons may apply for an OFAC specific license.  For example, financial institutions that fall outside the scope of 31 CFR § 515.572(a)(3) that seek to provide remittance forwarding services would not qualify for the authorization and would require a specific license.  Consistent with U.S. foreign policy, OFAC will prioritize specific license applications seeking authorization to enable remittances to flow more freely to the Cuban people via digital payments.  It is OFAC’s policy to deny specific license requests that involve transactions with CRL-listed entities for the purpose of collection, forwarding, or receipt of remittances.  Please see OFAC’s License Application Page for additional details regarding the specific licensing process.
 

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Yes, persons seeking to export software, services, or hardware to Iran or conduct other activities in support of internet freedom in Iran that are not exempt transactions or authorized by the general license in 31 CFR § 560.540 or other authorizations are encouraged to submit a specific license application to through the OFAC License Application Page

Date Updated: May 16, 2024

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A cloud-based service or software provider whose non-Iranian customers provide services or software to persons in Iran via the cloud may rely upon the authorization in 31 CFR § 560.540 to provide access to Iran, provided that such provider conducts due diligence based on information available to it in the ordinary course of business to confirm that the non-Iranian customer: (1) is not a person whose property and interests in property are blocked, except as authorized under paragraph (a)(6) of 31 CFR § 560.540; and (2) provides software and services that fall within one of the categories described in FAQ 1087, including activity authorized or exempt under the ITSR.

In instances where cloud-based services or software are used to support the exportation of services or software to Iran authorized under 31 CFR § 560.540, OFAC does not generally expect a cloud-based service or software provider to evaluate the ultimate end use or end user of the authorized software or services, provided the cloud-based provider conducts due diligence based on information available to it in the ordinary course of business.  For example, if a cloud-based service or software provider supports non-Iranian customers providing access in Iran to news websites or Virtual Private Networks (VPNs) that fall within one of the categories described in FAQ 1087, the cloud-based service or software provider need not evaluate whether the provision of access via the cloud involving Iranian end users is related to communication.  By contrast, if a U.S. cloud-based service or software provider supports non-Iranian customers providing certain enterprise management software to Iran, such as payroll management software, the cloud-based service or software provider would be expected to evaluate whether its support of the software is a prohibited export of software or services to Iran because payroll management software is not generally considered a qualifying software incident to communications.

Please note that 31 CFR § 560.540 does not authorize the importation into the United States of Iranian-origin software or the dealing in such software, including the hosting of Iranian-origin software on a mobile application store.  Persons seeking to engage in such activity may submit applications for specific licenses to OFAC that describe the nature of the software and the Iranian developers involved.

Date Updated: May 16, 2024

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Yes.  Section 560.540(a)(1) of the ITSR authorizes the exportation to Iran of fee-based or no-cost cloud-based services incident to the exchange of communications over the internet.  In addition, 31 CFR § 560.540(a)(2) authorizes the exportation to Iran of cloud-based software that is incident to, or enables services incident to, communications over the Internet.  Software exported under 31 CFR § 560.540(a)(2) either: (i) must be designated as EAR99 under the Export Administration Regulations, 15 CFR parts 730 through 774 (EAR), excluded from the EAR because it is described under 15 CFR § 734,3(b)(3), or classified under Export Control Classification Number (ECCN) 5D992.c; or (ii) if the software is not subject to the EAR because it is of foreign origin, must be the type of software that would be designated EAR99 or classified under ECCN 5D992.c if it were subject to the EAR.
For purposes of 31 CFR § 560.540, cloud-based services and software are determined to be incident to the exchange of communications over the Internet when they are used to support transactions authorized or exempt under the ITSR, including the following categories of activities: 

  • instant messaging, chat, email, social networking, sharing of photos and movies, web browsing, blogging, social media platforms, collaboration platforms, video conferencing, e-gaming platforms, e-learning platforms, automated translation, web maps, and user authentication services; 
  • the export, reexport, or provision of software and services listed in the categories (6) through (11) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications, including anti-virus and anti-malware software, anti-tracking software, mobile operating systems and related software, anti-censorship tools and related software; Virtual Private Network (VPN) client software and related software; and provisioning and verification software for Secure Sockets Layers (SSL) certificates and related software, provided that the software meets the relevant conditions of 31 CFR § 560.540, including applicable export control classification-related criteria;
  • transactions that are exempt from the prohibitions of the ITSR, including news outlets and media websites covered by the exemption for information or informational materials in 31 CFR § 560.210(c) of the ITSR; and
  • other transactions authorized under the ITSR, such as transactions necessary and ordinarily incident to publishing authorized pursuant to 31 CFR § 560.538, transactions for the conduct of the official business of certain international organizations pursuant to 31 CFR § 560.539, the sale and exportation of agricultural commodities, medicine, medical devices, and certain software and services pursuant to 31 CFR § 560.530, and transactions authorized pursuant to any general or specific licenses issued under the ITSR. 

Please note that 31 CFR § 560.540(a)(1) does not authorize the exportation of cloud-based services or software to the Government of Iran, except as specified in 31 CFR § 560.540(a)(6). 

Date Updated: May 16, 2024

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For the purposes of the determination of September 15, 2022 made pursuant to E.O. 14024, OFAC interprets the term “quantum computing sector of the Russian Federation economy” to include activities related to products and services in or involving the Russian Federation in research, development, manufacturing, assembling, maintenance, repair, sale, or supply of quantum computing, quantum computers, electronic assemblies thereof, or cryogenic refrigeration systems related to quantum computing.  OFAC also interprets the term “quantum computing sector of the Russian Federation economy” to include any of the following services when related to quantum computing:  infrastructure, web hosting or data processing services; custom computer programming services; computer systems integration design services; computer systems and data processing facilities management services; computing infrastructure, data processing services, web hosting services, and related services; repairing computer, computer peripherals, and communication equipment; other computer-related services; as well as the exportation, reexportation, sale, or supply, directly or indirectly, of quantum computing, quantum computers, electronic assemblies thereof, or cryogenic refrigeration systems related to quantum computing to or from the Russian Federation.

The determination regarding this sector pursuant to E.O. 14024 takes effect immediately.
 

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For the purposes of the determination, OFAC anticipates publishing regulations defining this term to include any of the following services when related to quantum computing, quantum computers, electronic assemblies thereof, or cryogenic refrigeration systems related to quantum computing:  infrastructure, web hosting, or data processing services; custom computer programming services; computer systems integration design services; computer systems and data processing facilities management services; computing infrastructure, data processing services, web hosting services, and related services; repairing computer, computer peripherals, or communication equipment; other computer-related services; as well as services related to the exportation, reexportation, sale, or supply, directly or indirectly, of quantum computing, quantum computers, electronic assemblies thereof, or cryogenic refrigeration systems related to quantum computing to any person located in the Russian Federation.  

For the purposes of the determination, OFAC also anticipates publishing regulations defining the term “person located in the Russian Federation” as set forth in FAQ 1058, as well as regulations defining the term “Russian person” to mean an individual who is a citizen or national of the Russian Federation, or an entity organized under the laws of the Russian Federation. 
 

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On September 15, 2022, the Director of OFAC, in consultation with the Department of State, issued a determination pursuant to Executive Order (E.O.) 14071, “Prohibitions Related to Certain Quantum Computing Services,” prohibiting the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of certain quantum computing services to any person located in the Russian Federation.  This determination takes effect on October 15, 2022.  This determination excludes from the scope of the prohibited services: (1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a United States person; and (2) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person.  For more information, please see FAQ 1084.  

On September 15, 2022, the Director of OFAC, in consultation with the Department of State, also issued a sectoral determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on individuals and entities that are determined to operate or have operated in the quantum computing sector of the Russian Federation economy.  The determination regarding this sector pursuant to E.O. 14024 takes effect immediately.
 

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No. GL 50 authorizes individuals with accounts at Russian financial institutions blocked pursuant to E.O. 14024 to unblock and lump sum transfer funds to an account at a non-designated financial institution.  Individuals do not need to provide official documentation proving they have closed their account at the blocked Russian financial institution when utilizing the GL.

Individuals who have filed a blocking report with OFAC and are availing themselves of GL 50 must file an unblocking report with OFAC within 10 business days of the unblocking in accordance with 31 CFR § 501.603(b)(3).  For guidance related to filing an initial report of blocked property, an annual report of blocked property, and an unblocking report, please see FAQs 49, 50, and 646, respectively, and 31 C.F.R. § 501.603.  Please note that the annual filing requirement for 2022 applies only to persons holding blocked property as of June 30 of this year.

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Since Russia’s further invasion of Ukraine beginning in February 2022, OFAC has blocked a number of Russian financial institutions pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy (see FAQ 966).  In addition, all property and interests in property of any financial institution that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.  Accordingly, U.S. persons are prohibited from transacting with these financial institutions unless the activity is exempt or authorized by OFAC.  

In practice, this means that accounts held by U.S. persons at any blocked Russian financial institutions generally are themselves considered blocked property, unless exempt.  This includes, for example, checking and savings accounts, credit cards, CDs, loans, and mortgages.  U.S. persons must stop utilizing such accounts and treat them as blocked, even if the designated Russian financial institution does not.  Additionally, within 10 business days of the blocking of the account or other property, U.S. persons are required to file a blocking report with OFAC describing any property or interests in property (e.g., accounts, etc.).  Information on the requirement to report blocked property, including accounts, and on filing initial and annual reports of blocked property with OFAC can be found at FAQs 49, 50, and 646, respectively, and 31 CFR § 501.603.  Please note that the annual filing requirement for 2022 applies only to persons holding blocked property as of June 30 of this year.

On August 19, 2022, OFAC issued Russia-related General License (GL) 50 authorizing individuals, wherever located, to engage in all transactions ordinarily incident and necessary to close their individual accounts held at a financial institution blocked pursuant to E.O. 14024.  GL 50 also authorizes the unblocking and lump sum transfer to the account holder of all remaining funds and other assets in the account at the blocked financial institution, including to an account held at a non-blocked financial institution.  Individuals may avail themselves of GL 50 to terminate their accounts with Russian financial institutions blocked pursuant to E.O. 14024 and repatriate the proceeds of any account closures.  Individuals who have filed a blocking report with OFAC and are availing themselves of GL 50 must file an unblocking report with OFAC within 10 business days of the unblocking in accordance with 31 CFR § 501.603(b)(3).

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Not necessarily.  Under the determinations, U.S. persons are prohibited from exporting, reexporting, selling, or supplying, directly or indirectly: management consulting; trust and corporate formation services; accounting services; quantum computing services; architecture services; and engineering services to persons located in the Russian Federation.  Thus, U.S. persons are prohibited from providing these services to companies located in the Russian Federation (“Russian companies”) in their capacity as employees.  However, the determinations do not prohibit U.S. persons from providing other services not covered by these determinations as part of their employment by Russian companies.

In addition, please note that the determinations exclude from the scope of the aforementioned services:  (1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a United States person; and (2) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person.

Date Updated: May 19, 2023 

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For transactions involving Tornado Cash that were initiated prior to its designation on August 8, 2022 but not completed by the date of designation, U.S. persons or persons conducting transactions within U.S. jurisdiction may request a specific license from OFAC to engage in transactions involving the subject virtual currency.  Applicants should be prepared to provide, at a minimum, all relevant information regarding these transactions with Tornado Cash, including the wallet addresses for the remitter and beneficiary, transaction hashes, the date and time of the transaction(s), as well as the amount(s) of virtual currency.  OFAC would have a favorable licensing policy towards such applications, provided that the transaction did not involve other sanctionable conduct.

In order to apply for a specific license to complete a transaction or withdraw virtual currency involving Tornado Cash that was deposited prior to its designation, or to engage in other transactions or dealings with Tornado Cash, you are encouraged to file a licensing request by visiting the following link: https://ofac.treasury.gov/ofac-license-application-page.

Updated: November 8, 2022

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OFAC is aware of reports following the August 8, 2022 designation of Tornado Cash that certain U.S. persons may have received unsolicited and nominal amounts of virtual currency or other virtual assets from Tornado Cash smart contracts, a practice commonly referred to as “dusting.”  Technically, OFAC’s regulations would apply to these transactions.  To the extent, however, these “dusting” transactions have no other sanctions nexus besides Tornado Cash, OFAC will not prioritize enforcement against the delayed receipt of initial blocking reports and subsequent annual reports of blocked property from such U.S. persons.  Persons who received a “dusting” transaction can also apply to OFAC for a specific license.

For guidance related to filing an initial and annual report of blocked property, please see FAQs 49, 50, and 646, respectively, and 31 C.F.R. § 501.603.  Please note that the annual filing requirement for 2022 applies only to persons holding blocked property as of June 30 of this year.

Updated: November 8, 2022

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No.  U.S. persons are prohibited from engaging in transactions involving Tornado Cash, including through the virtual currency wallet addresses that OFAC has identified.  If U.S. persons were to initiate or otherwise engage in a transaction with Tornado Cash, including or through one of its wallet addresses, such a transaction would violate U.S. sanctions prohibitions, unless exempt or authorized by OFAC.

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On August 8, 2022, OFAC designated the entity Tornado Cash pursuant to Executive Order (E.O.) 13694, as amended, for facilitating the laundering of proceeds of cybercrimes, including those committed by the Lazarus Group, a North Korea state-sponsored hacking group that was sanctioned in 2019.  On November 8, 2022, OFAC simultaneously designated Tornado Cash pursuant to E.O. 13722 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of the Government of North Korea and redesignated Tornado Cash pursuant to E.O. 13694, as amended, for facilitating the laundering of proceeds of cybercrimes, including those committed by the Lazarus Group, and as such the August 8, 2022 designation of Tornado Cash is no longer operative and is wholly replaced. As described in FAQs 561 and 562, OFAC may include as identifiers on the Specially Designated Nationals and Blocked Persons List (SDN List) specific virtual currency wallet addresses associated with blocked persons.  As part of the SDN List entry for Tornado Cash, OFAC included as identifiers certain virtual currency wallet addresses associated with Tornado Cash, as well as the URL address for Tornado Cash’s website.  The Tornado Cash website has since been deleted from the Internet, but it currently remains available through certain Internet archives.

While engaging in any transaction with Tornado Cash or its blocked property or interests in property is prohibited for U.S. persons, interacting with open-source code itself, in a way that does not involve a prohibited transaction with Tornado Cash, is not prohibited.  For example, U.S. persons would not be prohibited by U.S. sanctions regulations from copying the open-source code and making it available online for others to view, as well as discussing, teaching about, or including open-source code in written publications, such as textbooks, absent additional facts.  Similarly, U.S. persons would not be prohibited by U.S. sanctions regulations from visiting the Internet archives for the Tornado Cash historical website, nor would they be prohibited from visiting the Tornado Cash website if it again becomes active on the Internet.

Updated: November 8, 2022

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No.  OFAC has not designated PhosAgro PJSC and, based on information available to OFAC, PhosAgro PJSC is not owned 50% or more by blocked persons or otherwise considered the blocked property of Andrey Grigoryevich Guryev and Andrey Andreevich Guryev. 

As a general matter, agricultural and medical trade are not the target of sanctions imposed by the United States on Russia in response to its unprovoked and brutal war against Ukraine, and OFAC has issued General License 6B to authorize certain transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR) related to agricultural commodities (including fertilizer), agricultural equipment, medicine, and medical devices, among other things.  For information on exemptions and authorizations pursuant to the RuHSR related to fertilizer and other agricultural commodities, please see “OFAC Food Security Fact Sheet: Russia Sanctions and Agricultural Trade” and “Fact Sheet: Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine.”  
 

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No.  OFAC has not designated EuroChem Group AG and, based on information available to OFAC, EuroChem Group AG is not owned 50% or more by blocked persons or otherwise considered the blocked property of Andrey Igorevich Melnichenko. 

As a general matter, agricultural and medical trade are not the target of sanctions imposed by the United States on Russia in response to its unprovoked and brutal war against Ukraine, and OFAC has issued General License 6B to authorize certain transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR) related to agricultural commodities (including fertilizer), agricultural equipment, medicine, and medical devices, among other things.  For information on exemptions and authorizations pursuant to the RuHSR related to fertilizer and other agricultural commodities, please see “OFAC Food Security Fact Sheet: Russia Sanctions and Agricultural Trade” and “Fact Sheet: Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine.
 

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No.  OFAC has not designated Sheremetyevo International Airport and, based on information available to OFAC, Sheremetyevo International Airport is not owned 50% or more by blocked persons or otherwise considered the blocked property of Alexander Anatolevich Ponomarenko.

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Russia-related GL 46 authorizes transactions otherwise prohibited by section (1)(a)(i) of Executive Order (E.O.) 14071 related to the establishment, administration, participation in, and execution of an auction process, as announced by the EMEA Credit Derivatives Determination Committee, to settle credit derivative transactions with a reference entity of “the Russian Federation” (“the auction”).  

Examples of transactions that may be related to the auction include the submission and acceptance of bids and offers and physical settlement requests by auction participants and their customers, or the delivery and acceptance of the Russian Federation debt obligations and corresponding settlement amounts.

To promote the proper functioning of such auction, GL 46 also authorizes U.S. persons to purchase or receive Russian Federation debt obligations for the period beginning two business days prior to the announced date of the auction and ending eight business days after the conclusion of the auction. 

GL 46 also authorizes financial institutions, among others, to facilitate, clear, and settle transactions authorized by GL 46, including the transfer to, or purchase or receipt by, U.S. persons of Russian Federation debt obligations.  GL 46 does not require the clearance and settlement of such transactions to be completed within eight business days after the conclusion of the auction.  For example, a purchase by a U.S. person of Russian Federation debt obligations made on the seventh business day after the conclusion of the auction does not have to be settled or cleared by the eighth business day.  Accordingly, U.S. financial institutions may continue settling or clearing such transactions after the eighth business day following the conclusion of the auction. 

Financial institutions processing transactions pursuant to GL 46 may reasonably rely upon the information available to them in the ordinary course of business for the purposes of assessing whether a transaction is authorized by GL 46, provided that the financial institution does not know or have reason to know that a transaction is not in compliance with GL 46.  

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Through 12:01 a.m. eastern daylight time, October 20, 2022, Russia-related General License (GL) 45 (this content is no longer available) authorizes all transactions prohibited by section (1)(a)(i) of E.O. 14071 that are ordinarily incident and necessary to the wind down of financial contracts or other agreements that were entered into on or before June 6, 2022 and involve, or are linked to, debt or equity securities issued by an entity in the Russian Federation.

The authorized transactions include the purchase, or facilitating the purchase, by U.S. persons of debt or equity securities issued by an entity in the Russian Federation, if that purchase is ordinarily incident and necessary to the wind down of a financial contract or agreement entered into on or before June 6, 2022.  For example, U.S. persons may purchase securities issued by an entity in the Russian Federation in order to cover or close out a short position, per a securities lending agreement, if such agreement was entered into on or before June 6, 2022.  Please see FAQ 1054 for additional information on the scope of the prohibition in section 1(a)(i) of E.O. 14071, including permissible transactions related to the divestment or transfer of debt or equity securities to a non-U.S. person. 

Note that Russia-related GL 46 separately authorizes transactions related to the settlement of credit derivative transactions referencing “the Russian Federation” via an auction process.  For further information, please see FAQ 1072.  GL 45 does not authorize any transactions involving blocked persons, unless separately authorized.

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The determination of June 28, 2022 (as amended by the determination of December 22, 2023) issued pursuant to subsection 1(a)(i)(A) of amended E.O. 14068, “Prohibitions Related to Imports of Gold of Russian Federation Origin,” prohibits the importation into the United States of gold of Russian Federation origin.  Please note that per the determination, the importation into the United States of gold of Russian Federation origin that was located outside of the Russian Federation prior to June 28, 2022 is not prohibited.  For information regarding the term “Russian Federation origin,” please see FAQ 1019.

Date Updated: December 22, 2023

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Nicaragua GL 3authorizes U.S. persons to engage in transactions prohibited by the Nicaragua Sanctions Regulations, 31 CFR part 582 (the NSR), that are ordinarily incident and necessary to the wind down of transactions involving Empresa Nicaraguense de Minas (ENIMINAS), or any entity in which ENIMINAS owns, directly or indirectly, a 50 percent or greater interest (collectively, “Blocked ENIMINAS Entities”), through 12:01 a.m. eastern daylight time, July 18, 2022, provided that any payment to a blocked person must be made into a blocked account in accordance with the NSR.

After the expiration of this authorization, unless exempt or authorized by the Office of Foreign Assets Control, U.S. persons will be prohibited from engaging in transactions with the Blocked ENIMINAS Entities and must block such entities’ property or interests in property that are in, or thereafter come within, the United States, or the possession or control of a U.S. person.

Non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under the NSR for engaging in transactions with blocked persons, where those transactions would not require a specific license if engaged in by a U.S. person. 

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Yes.  U.S. persons, wherever located, are prohibited from exporting, reexporting, selling, or supplying, directly or indirectly, accounting services, which would include tax preparation and filing services, to any person located in the Russian Federation, unless otherwise exempt or authorized by OFAC.  Please see FAQ 1059 for more information.  Please note the determination excludes the provision by a U.S. person of any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a United States person, and any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person.

Updated: June 12, 2024

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Yes.  For the purposes of this determination, OFAC interprets management consulting services to include services related to strategic business advice; organizational and systems planning, evaluation, and selection; development or evaluation of marketing programs or implementation; mergers, acquisitions, and organizational structure; staff augmentation and human resources policies and practices; and brand management.  Please see FAQ 1034 for more information.

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The prohibitions imposed by the determination do not distinguish between new and existing trusts and companies.  Under the determination, U.S. persons are prohibited from providing trust and corporate formation services to persons located in the Russian Federation, regardless of whether the services are performed as part of the formation of a new trust or company, or as part of the administration or maintenance of an existing trust or company.  Please see FAQ 1034 for more information.

In addition, please note that the determination excludes from the scope of the aforementioned services: (1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a United States person; and (2) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person. 

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Under the determination, U.S. persons are prohibited from exporting, reexporting, selling, or supplying, directly or indirectly, trust and corporate formation services to persons located in the Russian Federation.  This prohibition on trust and corporate formation services does not, in and of itself, prohibit U.S. persons from serving on the board of directors of a company located in the Russian Federation.   

However, this determination would prohibit U.S. persons from providing nominee officer or director services in which a U.S. person is contracted to serve as a nominee officer, director, shareholder, or signatory of a legal person on behalf of a person located in the Russian Federation. 

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No, provided that the provision of services is not an indirect export to a person located in the Russian Federation.  For the purposes of these determinations, OFAC interprets the “indirect” provision of the prohibited services to include when the benefit of the services is ultimately received by a “person located in the Russian Federation.”

In contrast, OFAC would not consider to be prohibited the provision of services to a non-Russian company that has a physical presence and operations outside of the Russian Federation, including such a company owned or controlled by persons located in the Russian Federation, provided that the services will not be further exported or reexported to persons located in the Russian Federation.

For example, the following scenarios describe services that would be prohibited under the determination:

  • A U.S. corporate service provider administers a trust established under the laws of a U.S. state, where the trust exists to hold, sell, or purchase assets on behalf of a settlor, trustor, or beneficiary who is an individual ordinarily resident in Russia. 
  • A U.S. corporate service provider registers a limited liability company in a third country on behalf of an individual ordinarily resident in Russia for the purpose of holding real estate assets, and this company has no other physical presence or operations in the third country. 

The following scenarios illustrate services to a non-Russian subsidiary of a Russian person that would not be prohibited under the determination:

  • A U.S. accounting firm provides tax advisory and preparation services to the U.S. subsidiary of a Russian company.  This U.S. subsidiary has an office and employees in the United States and conducts business in the United States, and the services will not be exported or reexported to the Russian parent company.
  • A U.S. management consulting firm provides strategic business advice to the subsidiary of a Russian company located in a third country.  This subsidiary has an office and employees in the third country and conducts business in this third country, and the services will not be reexported to the Russian parent company.

Date Updated: May 19, 2023 

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For the purposes of section 1(a)(ii) of E.O. 14071, OFAC interprets “person located in the Russian Federation” to include persons in the Russian Federation, individuals ordinarily resident in the Russian Federation, and entities incorporated or organized under the laws of the Russian Federation or any jurisdiction within the Russian Federation.  

Please note that section 1(a)(ii) of E.O. 14071 prohibits the direct or indirect exportation, reexportation, sale, or supply from the United States, or by a United States person, wherever located, of such services determined pursuant to E.O. 14071.  For the purposes of E.O. 14071, OFAC interprets the “indirect” provision of such services to include when the benefit of the services is ultimately received by a “person located in the Russian Federation.”  Please see FAQ 1059 for more information.

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No.  Under 31 CFR § 515.572(a)(3), banking institutions, as defined in § 515.314, including U.S.-registered brokers or dealers in securities and U.S.-registered money transmitters, are authorized to provide services in connection with the collection, forwarding, or receipt of remittances authorized pursuant to the CACR, subject to certain conditions.  In addition, under § 515.570(h), banking institutions are authorized to unblock and return blocked remittances that would have been authorized under § 515.570(a) or (b).  Banking institutions may rely on the statements of their customers that remittance transactions are authorized unless they know or have reason to know a transaction is not authorized.  A banking institution is expected to conduct a level of due diligence commensurate with its overall risk profile and internal compliance policies and procedures with respect to a transaction involving Cuba or a Cuban national. 

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Effective June 9, 2022, in consultation with the Department of State, OFAC amended the CACR to implement elements of policy changes announced by the Administration on May 16, 2022 to increase support for the Cuban people.

Professional meetings and conferences in Cuba:  Effective June 9, 2022, OFAC amended 31 CFR § 515.564(a) to include a general license authorizing, subject to conditions, travel-related and other transactions incident to attending or organizing professional meetings or conferences in Cuba, such as   professional meetings or conferences to support expanded internet access and remittance processing and to provide additional support and training to independent Cuban entrepreneurs.  OFAC also amended and added cross-references to § 515.564(a) in notes to §§ 515.534, 515.542, 515.547, 515.572, 515.577, and 515.591.

Group people-to-people and other academic educational activities:  Effective June 9, 2022, OFAC amended § 515.565(a) to remove certain restrictions on authorized academic educational activities. OFAC also amended § 515.565(b) to authorize group people-to-people educational travel conducted under the auspices of an organization that is subject to U.S. jurisdiction and that sponsors such exchanges to promote people-to-people contact, provided such travelers are accompanied by an employee, paid consultant, or agent of the sponsoring organization.  Travel-related transactions authorized pursuant to § 515.565(b) must be for the purpose of engaging, while in Cuba, in a full-time schedule of activities that are intended to enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence from Cuban authorities; and will result in meaningful interactions with individuals in Cuba.  This amendment does not authorize individual people-to-people travel.  Travel for tourist activities is not permitted.

Remittances:  Effective June 9, 2022, OFAC amended § 515.570(a) to remove the $1,000 quarterly limit on family remittances to Cuban nationals who are close relatives.  OFAC also added § 515.570(b) to authorize donative remittances to Cuban nationals who are not prohibited officials of the Government of Cuba, prohibited members of the Cuban Communist Party, or close relatives of a prohibited official of the Government of Cuba or prohibited member of the Cuban Communist Party.  Finally, OFAC added a general license in § 515.570(h) authorizing the unblocking and return of previously blocked remittances, provided they would be authorized under the revised § 515.570(a) or (b).

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No, provided that (i) such funds are not specifically intended for new projects or operations in the Russian Federation and (ii) the entity located outside the Russian Federation derives less than 50 percent of its revenues from its investments in the Russian Federation.  

For the purposes of assessing the foregoing, U.S. persons, including U.S. financial institutions, may reasonably rely upon the information available to them in the ordinary course of business, including publicly available information such as an entity’s most recent quarterly or annual report.  For the purposes of determining the percentage of revenues derived from investments in the Russian Federation, revenues derived from the commercial sale of goods or services by an entity located outside of the Russian Federation to persons in the Russian Federation should not be included.  This approach is consistent with the guidance provided by the Office of Foreign Assets Control (OFAC) in FAQ 1049, which clarifies that OFAC does not consider the commercial sale of goods or services to persons in the Russian Federation by an entity located outside the Russian Federation to be new investment in the Russian Federation for purposes of the respective E.O. prohibitions. 

Unless exempt or otherwise authorized by OFAC, examples of transactions that OFAC considers to be “new investment” for the purposes of the respective E.O. prohibitions include:

  • The lending of funds to a special purpose vehicle established outside of the Russian Federation by a Russian entity for the purpose of raising funds intended to support new or expanded physical operations in the Russian Federation. 
  • The purchase (including on the secondary markets) of a debt or equity interest in an entity located outside of the Russian Federation that derives 50 percent or more of its revenues from its ownership of a subsidiary located in the Russian Federation (e.g., through dividends paid up by the Russian subsidiary to the non-Russian parent company).  
  • The purchase (including on the secondary markets) of a debt or equity interest in an entity located outside of the Russian Federation that derives 50 percent or more of its revenues from its ownership of real estate, a mine, or other physical property located in the Russian Federation. 

OFAC notes, however, the new investment prohibitions of the respective E.O.s do not prohibit U.S. persons from selling or divesting debt or equity securities issued by such entities to a non-U.S. person.  Moreover, U.S. financial institutions may clear and settle, or otherwise serve as market intermediaries in, such divestment transactions on the secondary market — including transactions between non-U.S. persons.  For the purposes of assessing whether certain purchases of debt or equity of an entity are permissible, U.S. financial institutions, including securities exchanges and other market intermediaries and participants, may reasonably rely upon the information available to them in the ordinary course of business.  

Examples of transactions that OFAC does not consider to be “new investment” for the purposes of the respective E.O. prohibitions include:

  • The purchase (including on the secondary markets) of a debt or equity interest in an entity located outside of the Russian Federation provided that the entity derives less than 50 percent of its revenues from its ownership of a subsidiary or physical operation located in the Russian Federation. 
  • The purchase (including on the secondary markets) of a debt or equity interest in an entity located outside of the Russian Federation whose revenue is exclusively derived from the commercial sale of goods or services to persons located in the Russian Federation.
  • Activities that would be considered “maintenance” pursuant to FAQ 1050.  

Date Updated: January 17, 2023

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Yes, the respective E.O.s prohibit U.S. persons from purchasing both new and existing debt and equity securities issued by an entity in the Russian Federation.  However, the new investment prohibitions of the respective E.O.s do not prohibit U.S. persons from selling or divesting debt or equity securities issued by an entity in the Russian Federation to a non-U.S. person (see FAQ 1049), including purchases of such debt or equity securities if ordinarily incident and necessary to the divestment or transfer of the debt or equity securities to a non-U.S. person.  U.S. financial institutions may clear and settle, or otherwise serve as market intermediaries in, divestment transactions on the secondary market—including transactions between non-U.S. persons.  

Please note that U.S. persons are not required to divest such securities and may continue to hold such previously acquired securities.  Moreover, the conversion of depositary receipts to underlying local shares of non-sanctioned Russian issuers would not be considered a prohibited “new investment” in the Russian Federation under the respective E.O.s.  

Additionally, the purchase of shares in a U.S. fund would not be considered a prohibited “new investment” under the respective E.O.s, unless the fund’s holdings of debt or equity securities issued by entities in the Russian Federation represent a 50 percent or more share by value of the fund.  Generally, the fund may also divest itself of these prohibited holdings.   

Date Updated: January 17, 2023

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Yes.  Transactions related to the divestment or the facilitation of divestment of a pre-existing investment in a project or operation in the Russian Federation are not prohibited by the new investment prohibitions of the respective E.O.s.  Such transactions may not involve a blocked person or otherwise prohibited transactions unless exempt or authorized by the Office of Foreign Assets Control (OFAC).

The respective E.O.s prohibit any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited if performed by a United States person or within the United States.  Such provisions do not prohibit U.S. persons from facilitating the wind down or divestment of an existing investment  in a project or operation in the Russian Federation.  For example, a U.S. financial institution is not prohibited from advising a client that seeks to divest from a project or operation in the Russian Federation (i.e., the seller in a transaction).  However, a U.S. person is prohibited from providing any approval, financing, facilitation, or guarantee to a non-U.S. person that seeks to invest in a project or operation in the Russian Federation (i.e., the buyer in such a transaction).  

Such provisions also do not prohibit U.S. persons from advising on the requirements of U.S. sanctions laws consistent with OFAC’s Guidance on the Provision of Certain Services Relating to the Requirements of U.S. Sanctions Laws.

For guidance related to divestment transactions in the secondary market involving debt or equity securities issued by an entity in the Russian Federation, please see FAQ 1054.

Updated: July 22, 2022

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Yes, provided that the use of the funds by the subsidiary or affiliate is consistent with maintenance, as described in FAQ 1050.  “Maintenance” does not include the expansion of pre-existing projects or operations beyond those in effect prior to the effective dates of the respective E.O. prohibitions.  Therefore, U.S. persons may not fund new or expanded projects or operations undertaken by their subsidiaries and affiliates located in the Russian Federation after the effective dates of the respective E.O. prohibitions.

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The prohibitions on “new investment” pursuant to the respective E.O.s do not prohibit the export or import of goods, services, or technology, or related sales or purchases, to or from the Russian Federation, provided that such transaction is made pursuant to ordinary commercial sales terms (e.g., a payment of an invoice for goods made within the contracted time period, where such payment does not involve ongoing participation in royalties or ongoing profits) (see FAQ 1049).  Such transactions can be supported through traditional trade finance products, including commercial letters of credit and documentary collections.  U.S. persons are not prohibited pursuant to the respective E.O.s from entering into new contracts or agreements for such transactions.

However, please note that U.S. persons are prohibited or restricted from exporting, reexporting, or importing certain goods and services involving the Russian Federation, as described by law (see, for example, section 1(a)(i) of E.O. 14068; see also FAQ 415).

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For the purposes of the respective E.O. prohibitions, “new investment” generally excludes the maintenance of investments in the Russian Federation that were made prior to the effective dates of the respective E.O. prohibitions (“pre-existing projects or operations”).  “Maintenance” of investments includes:  

  • Transactions to ensure continuity of pre-existing projects or operations located in the Russian Federation, including payments to employees, suppliers, landlords, lenders, and partners;
  • The preservation and upkeep of pre-existing tangible property in the Russian Federation; and
  • Activities associated with maintaining pre-existing capital investments or equity investments. 

As a general matter, “maintenance” includes all transactions ordinarily incident to performing under an agreement in effect prior to the effective date of the respective E.O. prohibitions (“pre-existing agreement”), provided that such transactions are consistent with previously established practices and support pre-existing projects or operations.  However, “maintenance” does not include the expansion of pre-existing projects or operations beyond those in effect prior to the effective dates of the respective E.O. prohibitions, even if pursuant to a pre-existing agreement, where such expansion occurs on or after the effective dates of the respective E.O. prohibitions.  Nor does “maintenance” include commitments pursuant to the exercise of rights under a pre-existing agreement where such commitment is made on or after the effective dates of the respective E.O. prohibitions.

In connection with maintenance activity, U.S. persons also may modify or alter pre-existing agreements, or enter into new contracts or agreements, provided that any transaction under such contracts or agreements are consistent with previously established practices and support pre-existing projects or operations.  For example, a pre-existing agreement may be modified, or new contract established, to substitute suppliers, conduct maintenance or repairs, or comply with new environmental or safety standards.  In assessing whether activity is consistent with past practice, the Office of Foreign Assets Control (OFAC) will consider all relevant facts and circumstances, including the transaction history between contract parties prior to the effective date of the respective E.O.s.

Note that maintenance activities must not involve blocked persons or other prohibited transactions unless exempt or otherwise authorized by OFAC.

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For the purposes of the respective E.O.s, the Office of Foreign Assets Control (OFAC) views “investment” as the commitment of capital or other assets for the purpose of generating returns or appreciation.  OFAC interprets “new” investment as such a commitment made on or after the effective date of the respective E.O. prohibitions.  As a general matter, new investment includes such commitments that are pursuant to an agreement entered on or after the effective dates of the respective E.O. prohibitions.  New investment also includes such commitments pursuant to the exercise of rights under an agreement entered into before the effective dates of the respective E.O. prohibitions, where such commitment is made on or after the effective dates of the respective E.O. prohibitions.  We note, however, that new investment does not include the maintenance of an investment made prior to the applicable effective dates of the respective E.O. prohibitions (see FAQ 1050). 

Unless exempt or otherwise authorized by OFAC, transactions that OFAC considers to be “new investment” for the purposes of the respective E.O. prohibitions include:

  • The purchase or acquisition of real estate in the Russian Federation, other than for noncommercial, personal use; 
  • Entry into an agreement requiring the commitment of capital or other assets for the establishment or expansion of projects or operations in the Russian Federation, including the formation of joint ventures or other corporate entities in the Russian Federation;
  • Entry into an agreement providing for the participation in royalties or ongoing profits in the Russian Federation;
  • The lending of funds to persons located in the Russian Federation for commercial purposes, including when such funds are intended to be used to fund a new or expanded project or operation in the Russian Federation;
  • The purchase of an equity interest in an entity located in the Russian Federation (see FAQs 1054 and 1055); and
  • The purchase or acquisition of rights to natural resources or exploitation thereof in the Russian Federation.

Examples of transactions that OFAC does not consider to be “new investment” for the purposes of the respective E.O. prohibitions include:

  • Entry into, performance of, or financing of a contract, pursuant to ordinary commercial sales terms, to sell or purchase goods, services, or technology to or from an entity in the Russian Federation (e.g., a payment of an invoice for goods, where payment is made within the contracted time period and such payment does not involve participation in royalties or ongoing profits);
  • Maintenance of an investment in the Russian Federation, where the investment was made prior to the effective date of the respective E.O. prohibitions, including maintenance of pre-existing entities, projects, or operations, including associated tangible property, in the Russian Federation (see FAQ 1050); and
  • Wind down or divestment of a pre-existing investment, such as a pre-existing investment in an entity, project, or operation, including any associated tangible property, located in the Russian Federation (see FAQs 1053 and 1054).

Even if a transaction is not a prohibited form of “new investment” pursuant to the respective E.O.s, U.S. persons engaging in the transaction must comply with all other relevant sanctions prohibitions, including those pursuant to Ukraine-/Russia-Related Sanctions Regulations and Russian Harmful Foreign Activities Sanctions Regulations (see, e.g., FAQ 415).  For example, the respective E.O.s include provisions prohibiting any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited if performed by a United States person or within the United States.  For more information, see FAQ 1053.

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No.  E.O. 13959, as amended, does not require U.S. financial institutions to block transactions.  However, transactions that would be prohibited under E.O. 13959, as amended (including an attempted sale of covered securities by a U.S. person made to effect the divestment of CMIC securities after the 365-day divestment period), must be rejected and reported to OFAC within 10 business days.  Consistent with FAQ 863, U.S. financial institutions may continue to intermediate purchases or sales by or from non-U.S. persons to or for non-U.S. persons.  

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U.S. persons who hold securities of CMICs identified pursuant to E.O. 13959, as amended, may continue to receive cash dividends and stock splits related to such covered securities, and U.S. financial institutions may continue to process such transactions.  However, purchases of CMIC securities effected through dividend reinvestments constitute purchases that are prohibited pursuant to E.O. 13959, as amended.  U.S. persons may, however, continue to facilitate the distribution of dividend reinvestments for non-U.S. persons after the relevant divestment period.

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U.S. persons are not required to divest their holdings of CMIC securities during the relevant 365-day divestment period and may continue to hold such securities after the divestment period.  E.O. 13959, as amended, permits purchases or sales made solely to effect the divestment of CMIC securities, but only during the 365-day divestment period.  Accordingly, any such purchase or sale is prohibited after the 365-day divestment period, absent OFAC authorization.

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For the purposes of Syria GL 22, the Annex in GL 22 identifies areas of northeast and northwest Syria in which activities described in GL 22 are authorized as of May 12, 2022.

Syria GL 22 does not authorize activities involving persons blocked pursuant to the Syrian Sanctions Regulations, 31 C.F.R. part 542, including the Government of Syria, or persons that may be subject to sanctions under other sanctions programs administered by OFAC (e.g., transactions with blocked persons designated under Executive Order (E.O.) 13224, as amended (OFAC’s counterterrorism authority), or E.O. 13894 (OFAC’s Syria-related authority)), unless exempt or otherwise authorized by OFAC.

Persons conducting activities in certain non-regime held areas in northeast and northwest Syria pursuant to Syria GL 22 can use OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) Search Tool to identify organizations and individuals explicitly included on the SDN List, as well as other individuals or entities explicitly subject to U.S. sanctions.  For more information on using OFAC’s SDN List Search Tool and assessing OFAC Name Matches, please see OFAC FAQs 5, 82, 246-253, 287, 369, 467, and 892

In addition, according to OFAC’s 50 Percent Rule entities are considered blocked if they are owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one or more blocked persons. 

OFAC would encourage any persons operating in certain non-regime held areas of northeast and northwest Syria pursuant to Syria GL 22 to use all information at their disposal when assessing their risk for sanctions exposure.  Supplementing internal due diligence information with an array of open-source material can be an effective compliance practice to aid in identifying risky counterparties involved in any in-country activity.  For more information on OFAC due diligence expectations and compliance programs, please see FAQs 25, 27-31 and A Framework for OFAC Compliance Commitments.
 

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Yes.  Transactions that are ordinarily incident and necessary to give effect to the activities authorized in Syria GL 22 are authorized.  Additionally, Syria GL 22 authorizes U.S. financial institutions to process transfers of funds related to authorized transactions and activities.  Such financial institutions may reasonably rely upon the information available to them in the ordinary course of business with regard to compliance with Syria GL 22, provided that the financial institution does not know or have reason to know that the funds transfer is not in compliance with the provisions of the GL.

In addition, foreign financial institutions do not risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019 for engaging in or facilitating transactions and activities that are otherwise authorized or exempt for U.S. persons under the Syrian Sanctions Regulations.  Please see FAQ 884 for additional information.
 

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Syria GL 22 authorizes certain activities in non-regime held areas of northeast and northwest Syria in the following economic sectors:  agriculture; information and telecommunications; power grid infrastructure; construction; finance; clean energy; transportation and warehousing; water and waste management; health services; education; manufacturing; and trade.  This includes activities in the areas of northeast and northwest Syria identified in the Annex in Syria GL 22, in support of transactions and activities that fall within the categories listed above, including:

  • the provision of agricultural-related services (such as the production of agricultural inputs, agricultural processing facilities, and the distribution of equipment and spare parts for machinery used in crop and livestock production); 
  • the provision of information and telecommunications-related services (such as reestablishment of telecommunications infrastructure, the promotion of internet connectivity for the Syrian people, and support for media and journalists);
  • the provision of power grid infrastructure and clean energy-related services (such as rehabilitation of distribution grids and lines, transformers or substations; and maintenance of power stations); 
  • activities to support construction-related services (such as repairs to residential buildings; rehabilitation of health facilities, schools, bakeries, irrigation pumps, and canals; and supplying associated spare parts, training, and support for maintenance of equipment);
  • the provision of financial-related services in support of the sectors outlined in Syria GL 22 (such as the provision of grants and loans, and entry into contracts to support private capital investments and trade);
  • the provision of transportation and warehousing-related services (such as rehabilitation of roads, bridges, waterways, and pipelines; and supplying associated technologies for alternative energy for transportation);
  • the provision of water and waste management-related services (such as rehabilitation of solid waste and medical disposal sites; and treatment of sewage and irrigation systems); 
  • the provision of healthcare and health-related services (such as the distribution of medical equipment, supplies, and pharmaceuticals; and technical training for and supervision of healthcare workers); 
  • the provision of educational-related services (such as the rehabilitation of schools; the provision of training and equipment support to local educators; training and equipment support to local officials on the operations and management of critical infrastructure; the provision of vocational and business management training; and the preservation and protection of cultural heritage sites); and
  • activities to support trade, including manufacturing of civilian-use goods directly benefiting the people in non-regime held areas of northeast and northwest Syria.

Additionally, Syria GL 22 authorizes U.S. financial institutions to process transfers of funds in support of the authorized transactions and activities outlined above.  

Separately, non-U.S. persons, including foreign financial institutions, do not risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019 for engaging in or facilitating transactions and activities that are otherwise authorized or exempt for U.S. persons under the SySR.  Please see FAQ 884 for additional information. 

Please note that this guidance does not apply to transactions and activities that may be subject to prohibitions under other sanctions programs administered by OFAC (e.g., transactions with persons blocked under OFAC’s counterterrorism authority (E.O. 13224, as amended) or OFAC’s Syria-related authority (E.O. 13894)), unless exempt or otherwise authorized by OFAC.  Any persons seeking to operate in non-regime held areas of northeast and northwest Syria must ensure their in-country activities do not involve prohibited transactions and activities or blocked persons, such as the Government of Syria or designated terrorist organizations.

For transactions and activities not otherwise authorized or exempt from sanctions, OFAC will consider license requests on a case-by-case basis.  Individuals, companies, or financial institutions with questions about engaging in or processing transactions related to this authorization can contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov.  Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490.

Additionally, U.S. and non-U.S. persons may need to obtain a license from the Department of Commerce’s Bureau of Industry and Security (BIS) for the export or reexport or certain items subject to Export Administration Regulations (EAR).  For further guidance regarding the exportation or reexportation of items to Syria, please contact BIS at (202) 482-4252.

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No.  Syria GL 22 does not remove any sanctions on the Assad regime and excludes transactions involving any person, including the Government of Syria, whose property or interests in property are blocked pursuant to the Syrian Sanctions Regulations or the Caesar Syria Civilian Protection Act of 2019 from the scope of the authorization.  Additional information on activities authorized pursuant to Syria GL 22 can be found in FAQ 1043.

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Syria GL 22 is intended to improve the economic conditions in non-regime held areas of northeast and northwest Syria and support ongoing stabilization efforts in the region.  This new authorization also builds upon the Administration’s strategy to defeat ISIS in the region. 

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GL 25D authorizes certain transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR).  In addition, GL 25D authorizes certain transactions from the United States or by U.S. persons, wherever located, to the Russian Federation that are incident to the exchange of communications over the internet and that are prohibited by the RuHSR.  With respect to software, hardware, and technology, GL 25D authorizes the exportation or reexportation, sale, or supply from the United States or by U.S. persons, wherever located, to the Russian Federation of software, hardware, or technology incident to the exchange of communications over the internet that is authorized for export to Russia by the Department of Commerce if it is subject to the Export Administration Regulations, 15 CFR parts 730-774 (EAR), or that would be eligible for a license exception or otherwise authorized for export to Russia by the Department of Commerce if it were subject to the EAR.  However, GL 25D explicitly excludes from the authorization any transactions involving Joint Stock Company Channel One Russia, Television Station Russia-1, Joint Stock Company NTV Broadcasting Company, Limited Liability Company Algoritm, New Eastern Outlook,  Oriental Review, or Garantex Europe OU, which are designated pursuant to Executive Order 14024

For further information on relevant authorizations, exemptions, and public guidance, please review OFAC’s Fact Sheet, “Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine.” 

Updated June 12, 2024

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Yes.  On May 8, 2022, OFAC designated Agropromyshlennyi Kompleks Voronezhskii OOO, Anninskii Elevator OOO, and Azovskaya Zernovaya Kompaniya OOO pursuant to Executive Order (E.O.) 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Joint Stock Company Moscow Industrial Bank (MIB), which was also designated on May 8, 2022 pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy.  Russia-related General License (GL) 6B authorizes, among other activities, certain transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), that are related to the sale, or transport of agricultural commodities, which includes transactions ordinarily incident and necessary to the exportation or reexportation of agricultural commodities to, from, or transiting the Russian Federation.  For additional information, please see the text of GL 6B.

For further information on relevant authorizations, exemptions, and public guidance, please review OFAC’s Fact Sheets, “Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine ” and “Russia Sanctions and Agricultural Trade”.

Date Updated: July 14, 2022

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For the purposes of the determination of May 8, 2022 made pursuant to E.O. 14024, OFAC interprets the following terms to include activities related to products and services in or involving the Russian Federation in the following:

  • “Accounting sector” – includes the measurement, processing, and evaluation of financial data about economic entities.  
  • “Trust and corporate formation services sector” – includes assisting persons in forming or structuring legal persons, such as trusts and corporations; acting or arranging for another person to act as directors, secretaries, administrative trustees, trust fiduciaries, registered agents, or nominee shareholders of legal persons; providing a registered office, business address, correspondence address, or administrative address for legal persons; and providing administrative services for trusts.
  • “Management consulting sector” – includes strategic business advice; organizational and systems planning, evaluation, and selection; development or evaluation of marketing programs or implementation; mergers, acquisitions, and organizational structure; staff augmentation and human resources policies and practices; and brand management.

The determination regarding these sectors pursuant to E.O. 14024 takes effect immediately.

Updated: May 11, 2022

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The prohibitions imposed by the determination of May 8, 2022 made pursuant to E.O. 14071take effect at 12:01 a.m. eastern daylight time June 7, 2022.

In addition, OFAC has issued General License 34 to authorize all transactions ordinarily incident and necessary to the wind down of the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of accounting, trust and corporate formation, and management consulting services to any person located in the Russian Federation, through 12:01 a.m. eastern daylight time, July 7, 2022.

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The term “credit rating services” means services related to assessments of a borrower’s ability to meet financial commitments, including analysis of general creditworthiness or with respect to a specific debt or financial obligation.

The term “auditing services” means examination or inspection of business records by an auditor, including checking and verifying accounts, statements, or other representation of the financial position or regulatory compliance of the auditee.

General License 35 authorizes certain transactions ordinarily incident and necessary to the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of credit rating or auditing services to any person located in the Russian Federation through 12:01 a.m. eastern daylight time, August 20, 2022. 

Updated: May 11, 2022

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For the purposes of the determination of May 8, 2022 made pursuant to E.O. 14071, OFAC anticipates publishing regulations defining these terms to include the following:

  • “Accounting services” includes services related to the measurement, processing, and evaluation of financial data about economic entities.  Please note that OFAC has issued General License 35 to authorize certain transactions ordinarily incident and necessary to the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of credit rating or auditing services to any person located in the Russian Federation through 12:01 a.m. eastern daylight time, August 20, 2022.  See FAQ 1035.
  • “Trust and corporate formation services” – includes services related to assisting persons in forming or structuring legal persons, such as trusts and corporations; acting or arranging for other persons to act as directors, secretaries, administrative trustees, trust fiduciaries, registered agents, or nominee shareholders of legal persons; providing a registered office, business address, correspondence address, or administrative address for legal persons; and providing administrative services for trusts.  Please note that all of these activities are common activities of trust and corporate service providers (TCSPs), although they may be provided by other persons.
  • “Management consulting services” – includes services related to strategic business advice; organizational and systems planning, evaluation, and selection; development or evaluation of marketing programs or implementation; mergers, acquisitions, and organizational structure; staff augmentation and human resources policies and practices; and brand management.

This determination excludes from the scope of the aforementioned services:  (1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a United States person; and (2) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person.

For the purposes of the prohibitions set forth in in the determination of May 8, 2022 made pursuant to E.O. 14071, OFAC anticipates publishing regulations defining the term “person located in the Russian Federation” as set forth in FAQ 1058.  For the purposes of the exclusion set forth in the determination of May 8, 2022 made pursuant to E.O. 14071, OFAC anticipates publishing regulations defining the term “Russian person” to mean an individual who is a citizen or national of the Russian Federation, or an entity organized under the laws of the Russian Federation.

Date Updated: September 15, 2022

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On May 8, 2022, the Director of OFAC, in consultation with the Department of State, issued a determination pursuant to Executive Order (E.O.) 14071, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” prohibiting the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of certain accounting, trust and corporate formation, and management consulting services to any person located in the Russian Federation.  This determination takes effect June 7, 2022.  For more information, please see FAQ 1034.

On May 8, 2022, the Director of OFAC, in consultation with the Department of State, also issued a sectoral determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on individuals and entities that operate or have operated in the accounting, trust and corporate formation services, or management consulting sectors of the Russian Federation economy.  This determination takes effect on May 8, 2022.  For further information, please see FAQ 1037.  

Date Updated: September 15, 2022

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Yes.  The Office of Foreign Assets Control (OFAC) issued two general licenses (GLs) related to TKB, which allow U.S. persons to engage in certain transactions involving TKB for specified time periods.

Russia-related GL 28 (this content is no longer available) authorizes U.S. persons to engage in certain transactions involving TKB, or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, that are ultimately destined for or originating from Afghanistan through 12:01 a.m. eastern daylight time, October 20, 2022. 

GL 28 also authorizes U.S. financial institutions to operate correspondent accounts on behalf of TKB, or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, provided such accounts are used solely to effect transactions ultimately destined for or originating from Afghanistan that are authorized by the GL.  This means that U.S. financial institutions are authorized to debit or credit correspondent accounts maintained for TKB, provided these debits or credits are for payments that are ultimately destined for or originating from Afghanistan.

In addition, through 12:01 a.m. eastern daylight time, May 20, 2022, Russia-related GL 29 authorizes certain transactions ordinarily incident and necessary to the wind down of transactions involving TKB, or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, regardless of whether such transactions are related to Afghanistan.  GL 29 does not authorize debits to blocked accounts.  For more information, please see FAQ 990.

For further information on relevant authorizations, exemptions, and public guidance, please review OFAC’s Fact Sheets, “Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine” and “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People.”
 

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Throughout OFAC’s sanctions list data products, such as the XML file, each entry is assigned a unique identification number (UID) as a means to help make sorting and filtering through information easier.  

In OFAC’s files, a UID is a numeric string that is associated with a single entry within a given system. OFAC's sanctions list data products are designed to be integrated into a relational database. As such, UIDs (which are typically considered “primary” or “foreign” keys) are assigned to all primary entries on the sanctions list(s) and are used to link the primary entry to its addresses, aliases, and other identifiers.

Occasionally, OFAC may only provide a list of UIDs in a Recent Actions notice when a clerical update is made to the sanctions list(s).  The purpose of such is to underscore the fact that these types of actions are solely administrative and that there have been no new entries added to OFAC's list(s).

For more information regarding the data specification and formatting of OFAC's files or on the use of UIDs within OFAC's files, please visit the following links: 


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Pursuant to the RuHSR and BSR, U.S. persons, including U.S. operators of credit card systems and U.S. acquirers, are prohibited from processing transactions involving certain sanctioned foreign financial institutions, unless exempt or authorized by OFAC.  Non-U.S. operators of credit card systems whose payment cards are issued by sanctioned foreign financial institutions may also be in violation of OFAC-administered sanctions regulations if they allow those cards to be used in the United States.

OFAC encourages U.S. persons, including U.S. operators of credit card systems and U.S. acquirers, to exercise caution and due diligence in dealing with non-U.S. operators of credit card systems that are known to host payment cards issued by sanctioned foreign financial institutions and whose payment cards are accepted in the United States.  Examples of due diligence measures may include requesting Bank Identification Numbers (BINs) associated with sanctioned foreign financial institutions, disabling those BINs from operation in the United States, and requesting that non-U.S. operators of credit card systems prevent the use of payment cards issued by sanctioned foreign financial institutions in the United States at the network level.
 

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Gold-related transactions involving the Russian Federation may be sanctionable under E.O. 14024 or other Russia-related sanctions authorities.  For example, E.O. 14024 authorizes sanctions against:

  • Persons determined to be responsible for or complicit in, or to have directly or indirectly engaged or attempted to engage in, deceptive or structured transactions or dealings to circumvent U.S. sanctions, including through the use of assets such as gold or other precious metals;  
  • Persons determined to operate or to have operated in the financial services sector of the Russian Federation economy, which could include those engaging in gold-related transactions involving the Russian Federation; and 
  • Persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, persons blocked under E.O. 14024.  This could include transactions in gold or other precious metals that involve such blocked persons.

In addition, gold-related transactions involving Russia or the Russian Federation may be prohibited under E.O. 14024 or other Russia-related sanctions authorities.  For example:

Sanctioned Russian persons are known to employ a wide variety of measures in their efforts to evade U.S. and international sanctions.  As such, U.S. persons, wherever located, including persons that process or facilitate gold-related transactions, must be vigilant against attempts to circumvent OFAC regulations and must take risk-based steps to ensure they do not engage in prohibited transactions. 

Violations of OFAC regulations may result in criminal or civil penalties.  OFAC is closely monitoring any efforts to circumvent or violate Russia-related sanctions, including through the use of gold or other precious metals, and is committed to using its authorities to act against sanctions evaders, and promote compliance.
 

Date Updated: June 28, 2022

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E.O. of March 11, 2022 prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation.  However, Russia-related General License (GL) 18 authorizes certain transactions that are ordinarily incident and necessary to the transfer of U.S. dollar-denominated banknotes for noncommercial, personal remittances from:  (i) the United States or a U.S. person, wherever located, to an individual located in the Russian Federation; or (ii) a U.S. person who is an individual located in the Russian Federation.

GL 18 authorizes methods of payment including withdrawals of U.S. dollar-denominated banknotes via automated teller machines and the hand carrying of U.S. dollar-denominated banknotes. 

Note that GL 18 does not authorize U.S. financial institutions to process transactions for the provision of U.S. dollar-denominated banknotes to foreign financial institutions for further distribution or supply to the Government of the Russian Federation or any person located in the Russian Federation.
 

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For the purposes of E.O. 14068, as amended by E.O. 14114, the Office of Foreign Assets Control anticipates publishing regulations defining these terms to include the following:

  • “Russian Federation origin” – see FAQ 1019.
  • “fish, seafood, and preparations thereof” – articles defined at Harmonized Tariff Schedule of the United States (HTSUS) subheadings 0301.11.00 to 0301.99.03; 0302.11.00 to 0302.99.00; 0303.11.00 to 0303.99.00; 0304.31.00 to 0304.99.91; 0305.20.20 to 0305.79.00; 0306.11.00 to 0306.99.01; 0307.11.00 to 0307.99.03; 0308.11.00 to 0308.90.01; 0309.10.05 to 0309.90.90; 1603.00.10; 1603.00.90; 1604.11.20 to 1604.32.40; 1605.10.05 to 1605.69.00; 0508.00.0000; 2301.20.0010; 2310.20.0090; 1504.10.20 to 1504.20.60; and 2106.90.9998, including any subsequent revisions to the list of HTSUS classifications.  See FAQ 1157 for additional definitions of certain categories of fish, seafood, and preparations thereof. 
  • “alcoholic beverages” – articles defined at HTSUS subheadings 2203.00.00; 2204.10.00 to 2204.30.00; 2205.10.30 to 2205.90.60; 2206.00.15 to 2206.00.90; 2207.10.30 to 2207.20.00; and 2208.20.10 to 2208.90.80, including any subsequent revisions to the list of HTSUS classifications.
  • “non-industrial diamonds” – articles defined at HTSUS subheadings 7102.31.00 and 7102.39.00, including any subsequent revisions to the list of HTSUS classifications.
  • “diamonds” - includes any diamonds classifiable under HTSUS subheadings 7102.10, 7102.31, and 7102.39 and under any other subheadings of the Harmonized Tariff Schedule of the United States specified in determinations.
  • “unsorted diamonds” – articles defined under HTSUS subheading 7102.10. 
  • “diamond jewelry” – articles defined under HTSUS heading 7113, incorporating diamonds. 

With respect to the export prohibitions set forth in section 1(a)(ii) of E.O. 14068, please consult the U.S. Department of Commerce, Bureau of Industry and Security, for guidance.

Date Updated: February 23, 2024

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E.O. of March 11, 2022 prohibits the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; and non-industrial diamonds of Russian Federation origin.  To the extent the import of such products of Russian Federation origin to jurisdictions outside of the United States does not involve a sanctioned person or an otherwise prohibited transaction, non-U.S. persons are not exposed to sanctions under E.O. of March 11, 2022.

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Yes.  E.O. 14068 prohibits the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; and non-industrial diamonds of Russian Federation origin.  It does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments outside the United States that were previously destined for the United States.

In addition, the Office of Foreign of Assets Control (OFAC) has issued Russia-related General License (GL) 17A to authorize the import, for a limited time, of certain items pursuant to pre-existing written contracts or written agreements (see FAQ 1023).  GL 17A provides such authorization for importing alcoholic beverages or non-industrial diamonds of Russian Federation origin until March 25, 2022 and authorization for importing fish, seafood, and preparations thereof of Russian Federation origin until June 23, 2022.  OFAC may issue specific licenses on a case-by-case basis to authorize shipments occurring after the expiry of GL 17A or for other activity outside the scope of this GL. 

(Updated March 24, 2022)

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E.O. 14068 prohibits the following activities:

  • the importation into the United States of the following products of Russian Federation origin:  fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds; and any other products of Russian Federation origin as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Commerce;
  • the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of luxury goods, and any other items as may be determined by the Secretary of Commerce, in consultation with the Secretary of State and the Secretary of the Treasury, to any person located in the Russian Federation;
  • new investment in any sector of the Russian Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, by a United States person, wherever located;
  • the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation; and
  • any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by sections 1(a)(i)-(iv) of E.O. 14068 if performed by a United States person or within the United States.

On December 22, 2023, E.O. 14068 was amended to provide for additional prohibitions on the importation and entry into the United States of certain categories of products.  See FAQ 1154 for additional information on how E.O. 14114 amends E.O. 14068.

Date Updated: February 23, 2024

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Yes.  The Office of Foreign Assets Control (OFAC) has imposed expansive sanctions actions against certain Russian entities and individuals pursuant to E.O. 14024, in addition to other authorities.  All U.S. persons are required to comply with OFAC regulations, regardless of whether a transaction is denominated in traditional fiat currency or virtual currency (see FAQ 560).

Sanctioned Russian persons are known to employ a wide variety of measures in their efforts to evade U.S. and international sanctions.  As such, U.S. persons, wherever located, including firms that process virtual currency transactions, must be vigilant against attempts to circumvent OFAC regulations and must take risk-based steps to ensure they do not engage in prohibited transactions.  For additional information regarding sanctions compliance best practices for the virtual currency industry, please see OFAC’s Sanctions Compliance Guidance for the Virtual Currency Industry.

U.S. persons, including virtual currency exchanges, virtual wallet hosts, and other service providers, such as those that provide nested services for foreign exchanges, are generally prohibited from engaging in or facilitating prohibited transactions, including virtual currency transactions in which blocked persons have an interest.  U.S. persons are further prohibited from engaging in or facilitating any transaction by a non-U.S. person that would be prohibited if performed by a U.S. person or within the United States, including virtual currency transactions involving the Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.  Among other activities, U.S. financial institutions are also generally prohibited from processing transactions, including virtual currency transactions, involving foreign financial institutions that are determined to be subject to the prohibitions of Directive 2 under Executive Order 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive).  For additional information regarding the Russia-related CAPTA Directive, please see FAQ 967.

Non-U.S. persons are also subject to certain OFAC prohibitions.  Such persons, for example, are prohibited from causing or conspiring to cause U.S. persons to violate U.S. sanctions, as well as engaging in conduct that evades or avoids a violation of OFAC sanctions.  Violations of OFAC regulations may result in criminal or civil penalties.

E.O. 14024 further authorizes sanctions against persons determined to be responsible for or complicit in, or to have directly or indirectly engaged or attempted to engage in, deceptive or structured transactions or dealings to circumvent U.S. sanctions, including through the use of digital currencies or assets, or the use of physical assets.  E.O. 14024 also authorizes sanctions against persons determined to operate or to have operated in the financial services or technology sectors of the Russian Federation economy, as well as persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, blocked persons.

OFAC is closely monitoring any efforts to circumvent or violate Russia-related sanctions, including through the use of virtual currency, and is committed to using its broad enforcement authorities to act against violations and to promote compliance.

For additional information regarding the application of sanctions to virtual currency, please see FAQs 559, 560, 561, 562, 563, 594, 646, 647, and 971, as well as OFAC’s Sanctions Compliance Guidance for the Virtual Currency Industry.

For additional Treasury guidance on Russia and sanctions evasion, please see FinCEN’s Alert on Increased Vigilance for Potential Russian Sanctions Evasion Attempts.

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No.  The importation prohibition of E.O. 14066 applies to the import of certain products of Russian Federation origin to the United States and excludes imports that are not of Russian Federation origin, even if such items transit through or depart from the Russian Federation.  The CPC transports crude oil through the CPC pipeline that is predominantly of Kazakh origin and that is marketed and loaded with a certificate of origin verifying that the crude is of Kazakh origin.  Any crude oil that is primarily of Russian Federation origin is marketed and loaded separately and certified as Russian origin.  For purposes of assessing whether crude oil marketed by the CPC is of Russian origin, U.S. persons may reasonably rely upon a certificate of origin, but should exercise caution if they have a reason to believe such certificate has been falsified.

Date Updated: 03/18/2022

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For the purposes of E.O. 14066, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine",  E.O. 14068, as amended by E.O. 14114, “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities,” and the determination “Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin” pursuant to E.O. 14071, the Office of Foreign Assets Control (OFAC) anticipates publishing regulations defining the term “Russian Federation origin” to include goods produced, manufactured, extracted, or processed in the Russian Federation, excluding any Russian Federation origin good that has been incorporated or substantially transformed into a foreign-made product.

For information on prohibitions related to new investment pursuant to Russia-related E.O. 14066, E.O. 14068, and E.O. 14071, please see FAQs 1049-1055. For information on the amendment to E.O. 14068, see FAQ 1154

Updated: April 12, 2024

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E.O. of March 8, 2022 prohibits the importation into the United States of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin.  To the extent the import of such products of Russian Federation origin outside of the United States does not involve a sanctioned person or an otherwise prohibited transaction, non-U.S. persons are not exposed to sanctions under E.O. of March 8, 2022.  However, targeted prohibitions or restrictions may apply to certain energy-related dealings with specified Russian persons under other sanctions authorities, such as E.O. 13662 or E.O. 14024.

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Yes.  GL 8C, which authorizes certain transactions “related to energy” involving specified Russian financial institutions, remains in effect until 12:01 eastern standard time, December 5, 2022, unless renewed.  However, GL 8C does not authorize any transactions prohibited by E.O. 14066 (see FAQs 976-978 and 1,010-1,012).

Updated: June 14, 2022

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Yes.  E.O. of March 8, 2022 prohibits the importation into the United States of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin.  It does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments that were previously destined for the United States.  In addition, the Office of Foreign of Assets Control (OFAC) has issued General License (GL) 16 to authorize the limited import of these items pursuant to pre-existing written contracts or written agreements through April 22, 2022 (see FAQ 1015).  Such shipments into the United States can still be imported in compliance with E.O. of March 8, 2022.  OFAC may issue specific licenses on a case-by-case basis to authorize shipments occurring after April 22, 2022 or other activity outside the scope of GL 16.

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Through 12:01 eastern daylight time, April 22, 2022, Russia-related General License (GL) 16 authorizes all transactions prohibited by E.O. of March 8, 2022 that are ordinarily incident and necessary to the importation of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin pursuant to written contracts or written agreements entered prior to March 8, 2022.  GL 16 does not authorize entry into new contracts.

Additionally, E.O. of March 8, 2022 does not prohibit transactions such as the unwinding of contracts or other business-related activities by U.S. persons to comply with the import ban imposed under E.O. of March 8, 2022.  Likewise, E.O. of March 8, 2022 does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments that were laden on or after March 8, 2022 and previously destined for the United States.

Note that all other prohibitions specified in E.O. of March 8, 2022 are effective immediately.

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No, only imports of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin into the United States are prohibited by E.O. of March 8, 2022, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine.”  Imports of other forms of energy of Russian Federation origin are not prohibited by E.O. of March 8, 2022.  In addition, E.O. of March 8, 2022 does not prohibit imports of non-Russian Federation origin, even if such items transit through or depart from the Russian Federation.  However, targeted prohibitions or restrictions may apply to certain energy-related dealings with specified Russian persons under other sanctions authorities, such as E.O. 13662 or E.O. 14024.

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E.O. of March 8, 2022 prohibits the following activities:

  • the importation into the United States of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin;
  • new investment in the energy sector in the Russian Federation by a United States person, wherever located; and
  • any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by E.O. of March 8, 2022, if performed by a United States person or within the United States.
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GL 8C authorizes energy-related transactions through 12:01 a.m. eastern standard time, December 5, 2022, unless renewed.  In the event that GL 8C is not renewed, OFAC intends to issue a general license authorizing the orderly wind down of activities covered by GL 8C.

Updated: June 14, 2022

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The Office of Foreign Assets Control (OFAC) encourages persons to connect with their financial institution regarding the status of any payment.  In addition, persons with questions about engaging in or processing transactions related to GL 8C can contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov.  Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490. 

Updated: June 14, 2022

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The energy sector of the Russian Federation economy itself is not subject to comprehensive sanctions.  However, prohibitions or restrictions may apply to certain energy-related transactions under several sanctions authorities, including prohibitions issued pursuant to E.O. 13662, E.O. 14024, E.O. 14066, E.O. 14071, and E.O. 14068.

Pursuant to E.O. 14066, the import into the United States of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin is prohibited; and U.S. persons, wherever located, are prohibited from new investment in the energy sector in the Russian Federation, among other things. 

E.O. 14066 does not prohibit transactions such as the unwinding of contracts or other business-related activities by U.S. persons to comply with the import ban imposed under E.O. 14066.  Likewise, E.O. 14066 does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments that were laden on or after March 8, 2022 and previously destined for the United States.  The Office of Foreign Assets Control (OFAC) has also authorized until April 22, 2022 certain transactions prohibited by E.O. 14066 (see FAQs 1013 – 1020).

In addition, pursuant to E.O. 14024, OFAC has imposed expansive sanctions on persons that operate or have operated in the financial services sector of the Russian Federation economy (see FAQ 966).  To limit the degree to which these financial services sector sanctions may inhibit energy-related transactions, OFAC has issued Russia-related General License (GL) 8C authorizing U.S. persons to process energy-related transactions involving the sanctioned Russian financial institutions identified in GL 8C.  GL 8C expires at 12:01 a.m. eastern standard time, December 5, 2022, unless renewed (see FAQs 976, 977, 978,  1011, and 1012).

Energy-related transactions authorized in GL 8C include payments connected with a variety of upstream and downstream activities, including the extraction, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, transport, or purchase of energy for import from the Russian Federation to countries other than the United States or for export to the Russian Federation, as well as financing, loading, or unloading related to such processes (see FAQ 977).  However, transactions related to new investment in the energy sector in the Russian Federation are not authorized pursuant to GL 8C.

Updated: June 14, 2022

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No.  E.O. 14065 targets the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”).  In determining whether a location is within the regions subject to sanctions, U.S. persons may reasonably rely on vetted information from reliable third parties, such as postal codes and maps.

U.S. persons engaging in activity that does not involve the Covered Regions are not subject to the prohibitions in E.O. 14065.  Please see FAQ 1006 for what prohibitions apply to the Covered Regions. 

Date Updated: May 05, 2022

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Yes.  Through 12:01 a.m. eastern daylight time on March 23, 2022, Ukraine-related General License 17 authorizes transactions that are ordinarily incident and necessary to the wind down of transactions involving the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine.  Given the comprehensive nature of the sanctions on these regions, these activities include the divestiture or transfer to a non-U.S. person of a U.S. person’s share of ownership in any pre-February 21, 2022 investment located in the DNR or LNR regions of Ukraine, and the winding down of operations, contracts, or other agreements in effect prior to February 21, 2022 involving the exportation, reexportation, sale, or supply of goods, services, or technology to, or importation of any goods, services, or technology from, the DNR or LNR regions of Ukraine.

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U.S. persons are authorized through a variety of Ukraine-related general licenses (GLs) to support certain humanitarian efforts and other activity in the Covered Regions, including transactions related to the export of food or medicine, the response to the Coronavirus Disease 2019 (COVID-19) pandemic, the official business of an international organization, or the activities of nongovernmental organizations, as well as personal remittances, telecommunications, internet services, and mail.

  • GL 18 authorizes certain transactions that are ordinarily incident and necessary to:  (1)  the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to the Covered Regions, or to persons in third countries purchasing specifically for resale to the Covered Regions; or (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19).
  • GL 19 authorizes certain transactions related to telecommunications that are ordinarily incident and necessary to the receipt or transmission of telecommunications in the Covered Regions, as well as certain transactions of common carriers involving the Covered Regions that are ordinarily incident and necessary to the receipt or transmission of mail and packages.
  • GL 20 authorizes transactions for the conduct of the official business of certain international organizations and entities.  For an organizational chart of the United Nations, which lists the Programmes, Funds, and Other Entities and Bodies, as well as the Specialized Agencies and Related Organizations covered by GL 19, see the following page on the United Nations website: https://www.un.org/en/pdfs/un_system_chart.pdf.
  • GL 21 authorizes certain transactions that are ordinarily incident and necessary to the transfer of noncommercial, personal remittances to or from the Covered Regions or for or on behalf of an individual ordinarily resident in the Covered Regions.  Further, GL 21 authorizes certain transactions that are ordinarily incident and necessary to maintaining, operating, or closing an account of an individual ordinarily resident in the Covered Regions.  U.S. depository institutions, U.S.-registered brokers or dealers in securities, and U.S.-registered money transmitters are authorized to process noncommercial, personal remittances pursuant to GL 21 regardless of whether the originator or beneficiary is an individual who is a U.S. person.  GL 21 is not limited to a specific method of payment.
  • GL 22 authorizes certain transactions that are ordinarily incident and necessary to the exportation or reexportation, directly or indirectly, from the United States or by U.S. persons, wherever located, to persons in the Covered Regions, of services incident to the exchange of personal communications over the internet as well as the export of software to enable such services.  However, GL 22 does not authorize the exportation or reexportation, directly or indirectly, of services or software with knowledge or reason to know that such services or software are intended for any person whose property and interests in property are blocked. 
  • GL 23 authorizes certain transactions that are ordinarily incident and necessary to the support of nongovernmental organizations’ activities in the Covered Regions, including activities related humanitarian projects to meet basic human needs, democracy building, education, non-commercial developments projects, and environmental and natural resource protection.  Such transactions may include the processing and transfer of funds, payment of taxes, fees, and import duties, and purchase or receipt of permits, licenses, or public utility services

Date Updated: 03/11/2022

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E.O. 14065 prohibits the following activities with the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine and such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”):  (i) new investment in the Covered Regions by a U.S. person, wherever located; (ii) the importation into the United States, directly or indirectly, of any goods, services, or technology from the Covered Regions; (iii) the exportation, reexportation, sale, or supply, directly or indirectly, from the United States or by a U.S. person, wherever located, of any goods, services, or technology to the Covered Regions; and (iv) any approval, financing, facilitation, or guarantee by a U.S. person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited if performed by a U.S. person, or within the United States.

In addition, E.O. 14065 authorizes sanctions against persons that:  operate or have operated in the Covered Regions since February 21, 2022; are or have been a leader, official, senior executive officer, or member of the board of directors since February 21, 2022 of an entity operating in the Covered Regions; are owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to E.O. 14065; or have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to E.O. 14065.  All property and interests in property of persons designated pursuant to E.O. 14065 that are or come within the United States or the possession or control of U.S. persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.  Additionally, any entities 50 percent or more owned, directly or indirectly, by one or more blocked persons are also blocked. 

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No, the Russia-related Sovereign Transactions Directive does not prohibit trading in the secondary markets for debt or equity of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, “Directive 4 entities”), provided that no Directive 4 entity is a counterparty to such a transaction.  Please note, however, that Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), prohibits U.S. financial institutions from participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Directive 4 entities.  However, the “new investment” prohibitions of E.O.14066, E.O. 14068, and E.O. 14071 prohibit U.S. persons from purchasing debt and equity securities issued by an entity in the Russian Federation.  Please see FAQ 1054.

Date Updated: May 19, 2023

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No.  Although the prohibitions of the Russia-related Sovereign Transactions Directive effectively immobilize any assets of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, the “Directive 4 entities”) that are held in the United States or by U.S. persons, wherever located, the Russia-related Sovereign Transactions Directive does not impose blocking sanctions on the Directive 4 entities.  Rather, U.S. persons must reject transactions involving the Directive 4 entities, unless exempt or authorized by OFAC.

Date Updated: May 19, 2023

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No. The Russia-related Sovereign Transactions Directive prohibits U.S. persons from engaging in any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities.  Effective February 28, 2022, U.S. persons may not engage in any transactions involving these entities unless exempt or authorized by the Office of Foreign Assets Control (OFAC), including debiting funds from restricted accounts.  This includes both direct and indirect transactions. The Russia-related Sovereign Transactions Directive also prohibits: (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive; and (2) any conspiracy formed to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive.  

In light of the current economic situation in Russia, U.S. persons should be on alert for nonroutine foreign exchange transactions that may indirectly involve entities subject to the Russia-related Sovereign Transactions Directive, including transactions that are inconsistent with activity over the 12 months prior to February 28, 2022. For example, the Central Bank of the Russian Federation may seek to use import or export companies to engage in foreign exchange transactions on its behalf and obfuscate its involvement. U.S. persons should also exercise caution in engaging in foreign exchange transactions on the Moscow Exchange given the current heightened risk that the Central Bank of the Russia Federation could be a counterparty to such transactions.

Date Updated: May 19, 2023

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The Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation are subject to several restrictions under the following directives:

  • Effective February 28, 2022, Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive), prohibits U.S. persons from engaging in any transaction involving these entities, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities.  The Russia-related Sovereign Transactions Directive was amended on May 19, 2023 to include a reporting requirement. (see FAQ 998)
  • Pursuant to Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), the following activities by a U.S. financial institution are prohibited:
    • As of June 14, 2021, participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; 
    • As of June 14, 2021, lending ruble or non-ruble denominated funds to the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; and
    • As of March 1, 2022, participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (see FAQ 888).
  • Effective August 19, 2019, the Russia-Related Directive (the “CBW Act Directive”) prohibits U.S. banks from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign and also prohibits U.S. banks from lending non-ruble denominated funds to the Russian sovereign.  The CBW Act Directive defines the term “Russian sovereign” as any ministry, agency, or sovereign fund of the Russian Federation, including the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance of the Russian Federation (see FAQs 675 and 676).   

The Russia-related Sovereign Transactions Directive includes prohibitions more expansive than the Russia-related Sovereign Debt Directive and the CBW Act Directive; however, it is important to note that each directive operates independently of the others and may have different effective dates.  Transactions involving these entities must comply with all three directives described above.

Date Updated: May 19, 2023

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OFAC issued Russia-related General License (GL) 8G to authorize certain energy-related transactions involving the Central Bank of the Russian Federation that would be prohibited by the Russia-related Sovereign Transactions Directive  (see FAQs 976 and 977). 

OFAC issued GL 13E to authorize U.S. persons to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation.  For further information on the types of transactions authorized by GL 13E, see FAQ 1118.  

OFAC also issued GL 14, authorizing certain transactions involving any Directive 4 entity where the Directive 4 entity’s sole function in the transaction is to act as an operator of a clearing and settlement system.  GL 14 does not authorize any transfer of assets to or from any Directive 4 entity, or any transaction where a Directive 4 entity is either a counterparty or beneficiary to the transaction.  In addition, GL 14 does not authorize any debit to an account on the books of a U.S. financial institution of any Directive 4 entity.  See FAQ 1003.

Note that GL 8G, GL 13E, and GL 14 continue to authorize against the Russia-related Sovereign Transactions Directive.

Date Updated: May 19, 2023

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The Russia-related Sovereign Transactions Directive prohibits U.S. persons from engaging in any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, “Directive 4 entities”), including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities.  Effective February 28, 2022, U.S. persons may not engage in any transactions involving these entities unless exempt or authorized by the Office of Foreign Assets Control (OFAC).  This includes both direct and indirect transactions involving any Directive 4 entity.  Prohibited transactions include trade or financial transactions and other dealings in which U.S. persons may not engage unless exempt or expressly authorized by OFAC.

The Russia-related Sovereign Transactions Directive also prohibits: (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive; and (2) any conspiracy formed to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive.

This action effectively immobilizes any assets of the Directive 4 entities that are held in the United States or by U.S. persons, wherever located, unless exempt or authorized by OFAC.  Effective February 28, 2022, U.S. financial institutions must reject transactions involving any Directive 4 entity, unless exempt or authorized by OFAC, and file a report within 10 business days in accordance with 31 CFR § 501.604.  OFAC issued general licenses that authorize certain limited transactions involving the Directive 4 entities (see FAQ 999).

On May 19, 2023, OFAC amended Directive 4 to require U.S. persons to submit a report to OFACreport@treasury.gov on or before June 18, 2023, and annually thereafter by June 30, regarding property in their possession or control in which any Directive 4 entity has an interest of any nature whatsoever, direct or indirect.  This reporting requirement is intended to identify assets of Directive 4 entities held by U.S. persons as of May 31, 2023, and annually thereafter, and is separate from the above-noted requirement under 31 CFR 501.604 to file reports on rejected transactions involving any Directive 4 entity. 

Entities determined to be subject to the Russia-related Sovereign Transactions Directive are listed on OFAC’s Non-SDN Menu-Based Sanctions (NS-MBS) List.

Date Updated: May 19, 2023

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No.  The United States has not lifted sanctions on the Taliban and the Haqqani Network.  The Taliban remains designated as a Specially Designated Global Terrorist (SDGT) under Executive Order (E.O.) 13224.  The Haqqani Network remains designated as an SDGT under E.O. 13224 and a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and Nationality Act (INA).  Transactions involving the Taliban or the Haqqani Network outside the scope of GLs 14, 15, 16, 17, 18, 19 and 20  remain prohibited.

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To the extent authorization is required, Afghanistan-related GL 20  authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  

Therefore, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related 1415161718 and 19.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 15, 16, 17, 18, and 19.  As with all OFAC GLs, GLs 14, 15, 16, 17, 18, 19 and 20 are “self-executing,” meaning that persons who determine that such activities are ordinarily incident and necessary to their authorized activity within the scope of the GL may proceed without further assurance from OFAC.

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Yes.  To the extent authorization is required, GL 20  authorizes financial transfers to or involving all governing institutions in Afghanistan — including but not limited to the DAB, Ministry of Education, Ministry of Energy and Water, Ministry of Finance, Ministry of Agriculture, Irrigation, and Livestock, and Ministry of Public Health — or to or involving state-owned or -controlled companies and enterprises in Afghanistan, including Da Afghanistan Breshna Sherkat (DABS), provided there are no financial transfers to the Taliban, the Haqqani Network, any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, or any blocked individual who is in a leadership role of a governing institution in Afghanistan, other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services, provided that such payments do not relate to luxury items or services.  GL 20 also authorizes receipt of payment from such governing institutions and state-owned or -controlled companies and enterprises in Afghanistan.

OFAC does not view financial transfers to governing institutions in Afghanistan or state-owned or -controlled companies and enterprises in Afghanistan as financial transfers to the Taliban, the Haqqani Network, any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, or any blocked individual who is in a leadership role of a governing institution in Afghanistan.  

Nothing in GL 20 affects the property or interests in property of Da Afghanistan Bank that are protectively blocked pursuant to Executive Order (E.O.) 14064 of February 11, 2022, “Protecting Certain Property of Da Afghanistan Bank for the Benefit of the People of Afghanistan.”
 

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For purposes of GL 20 , luxury items and services are those items and services that are not linked to activities that support basic human needs as defined with reference to United Nations Security Council Resolution 2615 (2021), for instance:  yachts, furs, designer clothing, and certain entertainment activities.  Luxury items  and services would not include, for example, phones, computers, or other similar items commonly used in connection with personal communication, education, activity by international organizations and non-governmental organizations, and other activity that supports basic human needs in Afghanistan.

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Generally speaking, when a designated individual has a leadership role in a governing institution, the governing institution itself is not considered blocked.  Accordingly, engaging in a routine interaction with an agency in which a blocked individual is an official, but that does not involve the blocked individual in question, is not prohibited. 

In this case, Afghanistan-related General License (GL) 20  authorizes all transactions involving Afghanistan or governing institutions in Afghanistan that would otherwise be prohibited by OFAC-administered sanctions on the Taliban or the Haqqani Network, subject to certain conditions.  GL 20 also authorizes the payment of taxes, fees, or import duties, or the purchase of permits, licensing, or public utility services to blocked individuals that are in leadership roles of governing institutions in Afghanistan, provided that such payments do not relate to luxury items  or services.

As an example, if an international organization (IO), nongovernmental organization (NGO), or company needs to make a customs payment to a governing institution in Afghanistan led by a blocked individual, that is authorized.  Similarly, if an IO, NGO, or company is signing a contract to provide services to or on behalf of that governing institution, and the blocked individual appointed to lead that governing institution needs to sign the contract in their official capacity on behalf of the governing institution, that is authorized.  However, if the blocked individual requests that funds be provided directly to them, other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services or financial transfers, that would not be authorized by GL 20.

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Transactions that are generally authorized by GL 20  to the extent authorization is required include:  

  • Commercial transactions involving Afghanistan, including imports from Afghanistan, exports to Afghanistan, and commercial transactions within or involving the geographical territory of Afghanistan; 
  • Dealings with all governing ministries and institutions in Afghanistan—including the Ministry of Education, Ministry of Energy and Water, Ministry of Finance, Ministry of Agriculture, Irrigation, and Livestock, Ministry of Public Health, Ministry of Economy, Ministry of the Interior, and Ministry of Refugees and Repatriations, and the Central Bank of Afghanistan (DAB);
  • Dealings with state-owned or -controlled companies and enterprises in Afghanistan, including the electrical utility Da Afghanistan Breshna Sherkat (DABS); 
  • Payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services, provided that such payments do not relate to luxury items or services;
  • Financial institutions’ processing of transactions to, from, or transiting Afghanistan, including clearing, settlement, and transfers through, to, or otherwise involving privately owned and state-owned Afghan banks;
  • Financial and professional services related to economic activity in Afghanistan;
  • Activities related to infrastructure maintenance or development in Afghanistan, including water, sanitation, energy, electricity, and public utilities;
  • Activities related to the development, maintenance, and operation of civilian transportation in Afghanistan, including safety and maintenance operations for civilian transportation in Afghanistan, including air traffic services, air navigation services, other transactions ordinarily incident and necessary to operations or use of airports, ground and landside operations, and rail or road construction or maintenance;
  • Transactions with respect to the receipt and transmission of telecommunications, mail, or parcels involving Afghanistan; 
  • Importation from and exportation to Afghanistan of any information or informational materials;
  • Transactions ordinarily incident to travel to or from Afghanistan; 
  • Transactions that are also authorized under Afghanistan-related GLs 1415161718 and 19 (for more information, see FAQs 928, 929, 930, 931, 949, 951, 953, 954, 957, 958, 959, 960, 961, 962, 963, and 996); and
  • Incidental contact with the Taliban or the Haqqani Network or any blocked individual who is currently in a leadership role in a governing institution in Afghanistan in connection with any of the authorized activities outlined above. 

Nothing in GL 20 relieves any person from compliance with any other federal laws or requirements of other federal agencies, including the International Traffic in Arms Regulations (ITAR) administered by the Department of State and the Export Administration Regulations (EAR) administered by the Department of Commerce, or from applicable international obligations.

GL 20 does not authorize financial transfers to the Taliban, the Haqqani Network, any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, or to any blocked individual who is in a leadership role of a governing institution in Afghanistan, other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services or financial transfers, provided that such payments do not relate to luxury items or services.  GL 20 also does not authorize transfers of luxury items or services to the Taliban, the Haqqani Network, any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, or any blocked individual who is in a leadership role of a governing institution in Afghanistan.

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The U.S. government recognizes that Afghanistan is facing a widespread humanitarian and economic crisis.  Treasury issued Afghanistan-related GL 20  to ensure that U.S. sanctions do not stand in the way of transactions and activities that support basic human needs of the people in Afghanistan.  GL 20 authorizes, to the extent authorization is required, activities necessary to support these needs, including, as established in the United Nations Transitional Engagement Framework (TEF) for Afghanistan, activities necessary to sustain essential social services such as health and education, preserve essential community systems, and promote livelihoods and social cohesion.  This GL helps provide clarity to financial institutions, nongovernmental organizations, international organizations, and private sector entities that they can facilitate the broad range of activities needed to mitigate further worsening of Afghanistan’s economic and humanitarian crisis.  This includes commercial activities in or involving Afghanistan.  For other specific examples of the kinds of activities authorized by General License 20, please see FAQ 992

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An authorization for transactions that are ordinarily incident and necessary to a transaction licensed pursuant to E.O. 14024 does not implicitly authorize a debit to a blocked account on the books of a U.S. financial institution.  Debits to an account on the books of a U.S. financial institution of a blocked person are only authorized as transactions ordinarily incident and necessary to a licensed transaction if such license explicitly authorizes such debits.

For example, General Licenses (GLs) 9 and 10  explicitly state that debits to accounts on the books of a U.S. financial institution of the blocked entities listed in the GLs are authorized to the extent ordinarily incident and necessary to effect the specified transactions authorized therein.  By contrast, GLs 3 and 11 do not explicitly authorize debits to accounts on the books of a U.S. financial institution of the blocked entities.
 

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No, so long as the terms of such debt (including the repayment period, the interest rate, and the amount) were contractually agreed to before the relevant sanctions effective date described in the Russia-related Entities Directive  and are not modified on or after the relevant sanctions effective date (FAQ 984).  As stated in FAQ 956, loans, contracts, or other agreements that use London Interbank Offered Rate (LIBOR) as a reference rate that are modified to replace such benchmark reference rate will not be treated as new debt for OFAC sanctions purposes, so long as no other material terms of the loan, contract, or agreement are modified. 

Some entities determined to be subject to the prohibitions of the Russia-related Entities Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024 or E.O. 13662.  It is important to note that each directive operates independently of the others.  For example, if a transaction involves a person subject to two separate directives, a U.S. person engaging in that transaction must comply with both directives.  
 

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No.  The Russia-related Entities Directive prohibits U.S. persons from engaging in only certain activities related to new debt of longer than 14 days maturity or new equity of the entities listed in Annex 1 to the Russia-related Entities Directive, or of entities otherwise determined to be subject to the prohibitions of the Russia-related Entities Directive, as explained in FAQ 984.  Please see FAQ 985 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive.

Some entities determined to be subject to the prohibitions of the Russia-related Entities Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024 or E.O. 13662.  It is important to note that each directive operates independently of the others.  For example, if a transaction involves a person subject to two separate directives, a U.S. person engaging in that transaction must comply with both directives.  
 

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If a U.S. person entered into a long-term credit facility or loan agreement prior to the relevant sanctions effective date described in the Russia-related Entities Directive, drawdowns and disbursements with repayment terms of 14 days or less are permitted.  In addition, drawdowns and disbursements whose repayment terms exceed 14 days are not prohibited if the terms of such drawdowns and disbursements (including the length of the repayment period, the interest rate applied to the drawdown, and the maximum drawdown amount) were contractually agreed to prior to the relevant sanctions effective date and are not modified on or after the relevant sanctions effective date.  U.S. persons may not deal in a drawdown or disbursement initiated on or after the relevant sanctions effective date with a repayment term that is longer than 14 days if the terms of the drawdown or disbursement were negotiated on or after the relevant sanctions effective date.  Such a newly negotiated drawdown or disbursement would constitute a prohibited extension of credit.  

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The term “debt” includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper.

The term “equity” includes stocks, share issuances, depositary receipts, or any other evidence of title or ownership.
 

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Yes.  The prohibitions of the Russia-related Entities Directive apply to any entity listed in Annex 1 to the Russia-related Entities Directive or otherwise determined to be subject to the prohibitions of the Russia-related Entities Directive, or their property or interests in property, which includes entities 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or more entities determined to be subject to the prohibitions of the Russia-related Entities Directive.

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The Russia-related Entities Directive prohibits certain dealings by U.S. persons or within the United States in new debt of longer than 14 days maturity or new equity of Russian entities determined to be subject to the prohibitions of the directive or their property or interests in property.  The prohibitions of the Russia-related Entities Directive are effective beginning on 12:01 a.m. eastern daylight time, March 26, 2022 for entities listed in Annex 1 to the Russia-related Entities Directive, or their property or interests in property.  For entities subsequently determined to be subject to the prohibitions of the Russia-related Entities Directive, the prohibitions are effective 12:01 a.m. eastern time 30 days following such determination.

Specifically, the Russia-related Entities Directive prohibits the following activities by U.S. persons or within the United States:  all transactions in, provision of financing for, and other dealings in new debt with a maturity of greater than 14 days or new equity of entities listed in Annex 1 to the Russia-related Entities Directive or otherwise determined to be subject to the prohibitions of the Russia-related Entities Directive, or their property or interests in property, where such debt or equity is issued on or after the relevant sanctions effective date.  Please see FAQ 985 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive.

Entity Type

Relevant Sanctions Effective Date

Entities listed in Annex 1 to the Russia-related Entities Directive, or their property or interests in property

On or after 12:01 a.m. eastern daylight time on March 26, 2022

Entities otherwise determined to be subject to the prohibitions of the Russia-related Entities Directive, or their property or interests in property

On or after 12:01 a.m. eastern time on the date that is 30 days after the date of such determination

These prohibitions apply to all new debt with a maturity of greater than 14 days and new equity irrespective of currency denomination.

In addition, the Russia-related Entities Directive prohibits:  (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the Russia-related Entities Directive; and (2) any conspiracy formed to violate any of the prohibitions of the Russia-related Entities Directive. 

Some entities determined to be subject to the prohibitions of the Russia-related Entities Directive may also be subject to prohibitions in other sanctions authorities, such as prohibitions of other directives issued under E.O. 14024, or directives issued under E.O. 13662.  It is important to note that each directive operates independently of the others.  For example, if a transaction involves a person subject to two separate directives, a U.S. person engaging in that transaction must comply with both directives.  

 

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In February 2022, OFAC issued two directives under E.O. 14024 regarding restrictions related to new debt or equity involving certain Russian Federation or Russia-related entities:

  • On February 22, 2022, OFAC issued Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), replacing and superseding Directive 1 under E.O. 14024 of April 15, 2021, to extend existing sovereign debt prohibitions to cover participation in the secondary market for ruble and non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (see FAQs 888 and 965).
  • On February 24, 2022, OFAC issued Directive 3 under E.O. 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) to prohibit all transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity issued on or after 12:01 a.m. eastern daylight time, March 26, 2022 by the entities listed in Annex 1 to that directive, or their property or interests in property.  These same prohibitions also apply to any entity subsequently determined to be subject to the prohibitions of the Russia-related Entities Directive, or its property or interests in property, beginning on or after 12:01 a.m. eastern time on the date that is 30 days after the date of such determination (see FAQ 984).

Entities determined to be subject to the prohibitions of these directives will be listed on the Non-SDN Menu-Based Sanctions List (NS-MBS List) (in addition to any other applicable sanctions lists maintained by OFAC).  Please see FAQ 985 regarding the applicability of OFAC’s 50 Percent Rule with respect to the Russia-related Entities Directive.  Listings on the NS-MBS List will denote when an entity has been determined to be subject to prohibitions, as well as when the prohibitions come into effect with respect to each entity.
 

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Unless otherwise authorized, U.S. persons may not buy or sell debt or equity of the Russian financial institutions blocked pursuant to Executive Order (E.O.) 14024.  Accordingly, a U.S. fund may not buy, sell, or otherwise engage in transactions related to debt or equity of such blocked Russian financial institutions, and must block such holdings, unless exempt or otherwise authorized by the Office of Foreign Assets Control (OFAC).  A U.S. fund that contains such blocked holdings generally is not itself considered a blocked entity unless such blocked holdings represent a 50 percent or more share by value of the fund.  If such blocked holdings do not represent a 50 percent or more share by value of the fund, U.S. persons may continue to invest in it, and the fund is not considered blocked.  The fund may divest itself of blocked holdings to the extent authorized by OFAC.

Date Updated: January 17, 2023

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General License (GL) 9A authorizes U.S. persons, until 12:01 a.m. eastern daylight time May 25, 2022, to engage in transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, that are ordinarily incident and necessary to dealings in debt or equity issued prior to February 24, 2022 of one or more of the following entities (“covered debt or equity”), provided that any divestment or transfer of, or facilitation of divestment or transfer of, covered debt or equity must be to a non-U.S. person:

  • State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB);
  • Public Joint Stock Company Bank Financial Corporation Otkritie; 
  • Sovcombank Open Joint Stock Company;
  • Public Joint Stock Company Sberbank of Russia;
  • VTB Bank Public Joint Stock Company;
  • Any entity owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one of the above entities.

This authorization includes the facilitation, clearing, and settling of transactions ordinarily incident and necessary to divest covered debt or equity to a non-U.S. person, including on behalf of U.S. persons.  Also, as part of a divestment transaction to a non-U.S. person, U.S. persons may engage in purchases of or investment in covered debt or equity if ordinarily incident and necessary to buy to cover a short position in such holdings.

To allow the closing of trades initiated before February 24, 2022, paragraph (b) of GL 9A authorizes all transactions that are ordinarily incident and necessary to facilitating, clearing, and settling trades of covered debt or equity through 12:01 a.m. eastern daylight time May 25, 2022, provided such trades were placed prior to 4:00 p.m. eastern standard time on February 24, 2022, including debits to accounts on the books of U.S. financial institutions of certain blocked entities.  

GL 9A also authorizes U.S. persons to receive interest, dividend, or maturity payments on debt or equity of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation through 12:01 a.m. eastern daylight time on May 25, 2022.  After May 25, 2022, U.S. persons would require a specific license to continue to receive such payments.  

Certain transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, are not authorized by GL 9A.  Please see GL 9A for additional details.  Please also see GL 10A with respect to authorizations related to certain derivative contracts. 

For purposes of assessing whether certain transactions are authorized under GL 9A or GL 10A, U.S. persons—including financial institutions, registered broker-dealers in securities, securities exchanges, and other market intermediaries and participants—may rely upon the information available to them in the ordinary course of business, including reasonable reliance on information about the underlying transaction provided by the parties thereto.  However, U.S. persons should also exercise caution in engaging in foreign exchange transactions on the Moscow Exchange given the current heightened risk that the Central Bank of the Russia Federation could be a counterparty to such transactions (see FAQ 1002). 

Date Updated: March 02, 2022

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OFAC evaluates a range of factors when developing sanctions targets, consistent with foreign policy and national security goals.  In the context of blocking sanctions, non-U.S. persons may be exposed to sanctions risk in relation to activities with persons subject to blocking sanctions pursuant to E.O. 14024.  Under E.O. 14024, non-U.S. persons may be designated if they have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, certain activities, a person whose property and interests in property are blocked pursuant to E.O. 14024, or (in certain circumstances) a blocked government.  Please see sections 1(a)(vi) and 1(b) of E.O. 14024. 

Non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under E.O. 14024 for engaging in transactions with persons subject to the prohibitions of the directives under E.O. 14024.  Moreover, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under E.O. 14024 for engaging in transactions with blocked persons, where those transactions would not require a specific license if engaged in by a U.S. person.  Note, however, that E.O. 14024 and the directives under E.O. 14024 prohibit any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of those directives, as well as any conspiracy formed to violate any of the prohibitions of those directives.  OFAC will not view as “evading or avoiding” efforts by non-U.S. persons to comply with U.S. sanctions by replacing sanctioned suppliers or service providers (including financial institutions) with non-sanctioned persons.
 

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Yes, U.S. persons supporting activities undertaken for the official business of certain international organizations or entities, certain humanitarian-related trade, or the response to the COVID-19 pandemic may continue to engage in such activity involving persons sanctioned pursuant to E.O. 14024 through a variety of OFAC authorizations or exemptions, as described below.

Consistent with section 9 of E.O. 14024, transactions for the conduct of the official business of the Federal Government or the United Nations (including its specialized agencies, programs, funds, and related organizations) by employees, grantees, and contractors thereof are exempt from the sanctions prohibitions of E.O. 14024.

Additionally, OFAC has issued General License (GL) 5, authorizing transactions for the conduct of the official business of certain international organizations and entities.  

OFAC also issued GL 6, which authorizes, subject to certain conditions, transactions that are ordinarily incident and necessary to:  (1) the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to, from, or transiting the Russian Federation; or (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19).

While certain Russian financial institutions are subject to sanctions under E.O. 14024, the financial services sector of the Russian Federation economy is not comprehensively sanctioned (see FAQ 964).  Accordingly, U.S. persons may also use non-sanctioned Russian financial institutions to process these transactions.

Note that the authorizations and exemptions described above do not extend to prohibitions applied to persons sanctioned pursuant to any other sanctions authorities implemented by OFAC, such as E.O. 13662.

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GLs 6A, 7A, and 8C do not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of entities subject to the prohibitions of Directive 2 under E.O.  14024 , “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive).  Consequently, in order for a U.S. financial institution to engage in transactions authorized under these GLs (e.g., a funds transfer related to energy), all such funds transfers must be processed indirectly through a non-sanctioned, non-U.S. financial institution.  

Examples of authorized and prohibited funds transfers under GLs 6A, 7A, and 8C include:

 

Payment from third-country originator

Authorized payment from third-country originator to beneficiary with an account at a sanctioned institution:

Prohibited payment from third-country originator to beneficiary with an account at a sanctioned institution: 

 

Payment from U.S. originator

Authorized payment from U.S. originator to beneficiary with an account at a sanctioned institution:

Prohibited payment from U.S. originator to beneficiary with an account at a sanctioned institution: 

In each of the above examples, the underlying funds transfer must be authorized under the applicable GL.
 

Updated: June 14, 2022

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For the purposes of GL 8C,  the term “related to energy” means the extraction, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, transport, or purchase of petroleum, including crude oil, lease condensates, unfinished oils, natural gas liquids, petroleum products, natural gas, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels, or uranium in any form, as well as the development, production, generation, transmission, or exchange of power, through any means, including nuclear, thermal, and renewable energy sources. This definition remains unchanged from GL 8.

Updated: June 14, 2022

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General License (GL) 8J authorizes certain transactions “related to energy” (as defined in the GL; see also FAQ 977) involving the following entities (collectively, “Covered Entities”):

  • State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB);
  • Public Joint Stock Company Bank Financial Corporation Otkritie;
  • Sovcombank Open Joint Stock Company;
  • Public Joint Stock Company Sberbank of Russia;
  • VTB Bank Public Joint Stock Company; 
  • Joint Stock Company Alfa-Bank;
  • Public Joint Stock Company Rosbank;
  • Bank Zenit Public Joint Stock Company;
  • Bank Saint-Petersburg Public Joint Stock Company;
  • National Clearing Center (NCC);
  • Any entity owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one of the above entities; and
  • The Central Bank of the Russian Federation.

GL 8J does not authorize any transaction prohibited by Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive).  In addition, GL 8C does not authorize any debit to an account on the books of a U.S. financial institution of the Central Bank of the Russian Federation.  Further, GL 8J does not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of foreign financial institutions subject to the prohibitions of Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (the “Russia-related CAPTA Directive”).  Consequently, in order for a U.S. financial institution to engage in transactions authorized by GL 8C, all funds transfers related to energy involving one or more Covered Entities must be processed indirectly through a non-sanctioned, non-U.S. financial institution.  Please see FAQ 978 for examples of authorized and prohibited transactions flows under certain GLs, including GL 8J.

For purposes of assessing whether certain transactions are authorized under GL 8J, U.S. persons may rely upon the information available to them in the ordinary course of business, including reasonable reliance on information about the underlying transaction provided by the parties thereto.

GL 8J is valid until 12:01 eastern daylight time, November 1, 2024 unless renewed.  Persons unable to wind down prohibited transactions with the Covered Entities by November 1, 2024 are encouraged to approach the Office of Foreign Assets Control, which may consider renewing GL 8J.  Please see FAQs 977, 978, 1010, 1111, and 1012 for additional guidance related to GL 8J.

GL 8J provides authorization solely under E.O. 14024.  Therefore, U.S. financial institutions that rely on the authorization provided in GL 8J to process transactions related to energy must also comply with the prohibitions of E.O. 14066, E.O. 14068, and E.O. 14071 (see FAQs 1013, 1014 and 1015).

Updated: June 12, 2024

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For certain Russian financial institutions blocked in February 2022 pursuant to E.O. 14024, a short-term wind-down period is authorized.  General License (GL) 3 authorizes a wind-down period of 30 days for transactions involving State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), and GL 11 authorizes a wind-down period of 30 days for transactions involving VTB Bank Public Joint Stock Company, Public Joint Stock Company Bank Financial Corporation Otkritie, or Sovcombank Open Joint Stock Company.  These authorizations also apply to any entity in which these financial institutions own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. 

GLs 3 and 11 authorize U.S. persons to engage in transactions ordinarily incident and necessary to exit operations, contracts, or other agreements that were in effect prior to the date of blocking involving the specified blocked Russian financial institutions, provided that such transactions do not involve a debit to a blocked account on the books of a U.S. financial institution (see FAQ 990).  For example, a U.S. financial institution may take steps necessary to collect on outstanding loans made to a blocked person, including exercising rights to any collateral related thereto, as authorized wind-down activity, provided the transaction does not involve a debit to a blocked account on the books of a U.S. financial institution (unless separately authorized).  A U.S. financial institution may also take steps necessary to pay outstanding loans, provided that, if such payment is for the benefit of a blocked person, it must be transferred into a blocked account.  Similarly, a U.S. financial institution may take steps necessary to close a correspondent account maintained for a blocked person; however, funds in the correspondent account may not be returned to the blocked person, and must remain blocked, absent separate authorization from OFAC.

GLs 3 and 11 authorize only new or continued business activities that are ordinarily incident and necessary to wind-down activities.  Wind-down activities do not include the continued processing of funds transfers, securities trades, or other transactions involving a blocked person that were part of ongoing business activities prior to the imposition of sanctions, unless separately authorized (see, e.g., GLs 8, 9, and 10).  Moreover, GLs 3 and 11 do not apply to all Russian financial institutions blocked in February 2022, such as Promsvyazbank Public Joint Stock Company or Joint Stock Commercial Bank Novikombank, or transactions involving other persons blocked pursuant to E.O. 14024, other than the blocked Russian financial institutions specified in GLs 3 and 11.

In addition to GLs 3 and 11, OFAC issued GL 12 to authorize U.S. persons to reject, rather than block, prohibited transactions involving specified blocked Russian financial institutions for 30 days.  This authorizes, for example, a U.S. financial institution to reject, rather than block, an attempted unauthorized funds transfer until the expiration of GL 12.  The authorization provided in GL 3 expires at 12:01 eastern daylight time, March 24, 2022.  The authorizations provided in GLs 11 and 12 expire at 12:01 a.m. eastern daylight time, March 26, 2022.

For more information on the prohibitions that apply to Russian financial institutions blocked pursuant to E.O. 14024 in February 2022, or related authorizations, please see FAQ 974.

For guidance regarding transactions involving securities and derivatives contracts related to the blocked persons listed above, see FAQ 982.
 

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On February 22, 2022, the Office of Foreign Assets Control (OFAC) designated specified Russian financial institutions pursuant to E.O. 14024 , including the State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), Promsvyazbank Public Joint Stock Company, and many of their subsidiaries.  OFAC designated additional Russian financial institutions on February 24, 2022, including VTB Bank Public Joint Stock Company, Public Joint Stock Company Bank Financial Corporation Otkritie (Otkritie), Sovcombank Open Joint Stock Company (Sovcombank), Joint Stock Commercial Bank Novikombank, and many of these financial institutions’ subsidiaries.  As a result, all property and interests in property of these entities in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked and must be reported to OFAC.  In addition, all property and interests in property of any entity that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.  Accordingly, U.S. persons, including U.S. financial institutions, are prohibited from transacting with these entities unless exempt or authorized by OFAC.  

OFAC issued several Russia-related general licenses (GLs) authorizing transactions involving specified blocked Russian financial institutions, including:
•    GL 2 : authorizing certain transactions involving VEB related to servicing obligations of certain Russian sovereign debt; 
•    GL  3: authorizing the wind down of certain transactions involving VEB until 12:01 a.m. eastern daylight time, March 24, 2022;
•    GL  11: authorizing the wind down of certain transactions involving VTB Bank Public Joint Stock Company, Otkritie, and Sovcombank until 12:01 a.m. eastern daylight time, March 26, 2022; and
•    GL  12: authorizing the rejection (rather than blocking) of certain transactions involving VTB Bank Public Joint Stock Company, Otkritie, and Sovcombank until 12:01 a.m. eastern daylight time, March 26, 2022.

Note that these GLs do not authorize certain activities with all blocked Russian financial institutions; nor does each GL authorize certain activities with the same group of blocked Russian financial institutions.  For example, the GLs listed above do not authorize any transactions involving Promsvyazbank Public Joint Stock Company or Joint Stock Commercial Bank Novikombank, and GLs 2 and 3  relate only to VEB.  

Other GLs that may be applicable to one or more of the Russian financial institutions blocked in February 2022 include:

•    GL  5: authorizing transactions related to the official business of certain international organizations and other entities; 
•    GL  6: authorizing certain transactions related to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates, or the prevention, diagnosis, or treatment of COVID-19; 
•    GL  7: authorizing overflight payments, emergency landings, and air ambulance services;

•    GL  8A: authorizing transactions related to energy; 
•    GL  9A: authorizing transactions related to dealings in certain debt and equity until 12:01 a.m. eastern daylight time, May 25, 2022; and
•    GL  10A: authorizing certain transactions related to derivative contracts until 12:01 a.m. eastern daylight time, May 25, 2022. 

Please consult each GL for further information regarding its scope.  

On March 1, 2022, OFAC issued the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), which incorporate GL 5 in section 587.510 of the RuHSR.

Additionally, consistent with section 9 of E.O. 14024, transactions for the conduct of the official business of the Federal Government or the United Nations (including its specialized agencies, programs, funds, and related organizations) by employees, grantees, and contractors thereof are exempt from the sanctions prohibitions of E.O. 14024.

Date Updated: March 02, 2022

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With respect to foreign financial institutions subject to the prohibitions of Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive), including Public Joint Stock Company Sberbank of Russia, obligations under this directive apply to U.S. financial institutions only.  U.S. individuals and companies that are not “U.S. financial institutions,” as defined in the Russia-related CAPTA Directive, are not prohibited from processing transactions involving foreign financial institutions solely subject to the Russia-related CAPTA Directive.  

With respect to the Russian financial institutions blocked on February 22 and 24, 2022 pursuant to E.O. 14024, General Licenses (GLs) 3 and 11 authorized U.S. persons to engage in transactions ordinarily incident and necessary to terminate their relationship with specified blocked Russian financial institutions, including withdrawing funds and securities, cancelling letters of credit, and amending or cancelling performance guarantees.  For additional information, please see FAQ 975.  Upon the respective expiration of GLs 3 and 11, U.S. persons were prohibited from transacting with the blocked Russian financial institutions, unless exempt or authorized by OFAC. 

Date Updated: December 22, 2023

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Under the Russia-related CAPTA Directive, U.S. financial institutions are prohibited from the opening or maintaining of a correspondent account or payable-through account for or on behalf of, or from processing of a transaction involving, a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive.  The term “U.S. financial institution,” as defined in the directive, includes foreign branches of U.S. financial institutions, but not their foreign subsidiaries.  Note, however, that the Russia-related CAPTA Directive prohibits any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of this directive, as well as any conspiracy formed to violate any of the prohibitions of this directive.  OFAC will not view as “evading or avoiding” efforts by non-U.S. persons to comply with U.S. sanctions by replacing sanctioned suppliers or service providers (including financial institutions) with non-sanctioned persons.

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No.  The prohibitions of the Russia-related CAPTA Directive apply with respect to any currency.  For example, a foreign branch of a U.S. financial institution may not open or maintain a correspondent account for or on behalf of, or process a transaction involving, a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive, even if that account is denominated in a currency other than U.S. dollars, such as euros.  

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Yes.  The prohibitions of the Russia-related CAPTA Directive apply to a U.S. financial institution’s opening or maintaining of a correspondent account or payable-through account for or on behalf of, or processing of a transaction involving, any FFI, wherever located outside of the United States, determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property—which includes FFIs 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or more FFIs determined to be subject to the prohibitions of the Russia-related CAPTA Directive.  This includes, for example, banking subsidiaries that are 50 percent or more owned by Public Joint Stock Company Sberbank of Russia and located outside of the United States.  

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Yes.  The prohibitions of the Russia-related CAPTA Directive apply to any foreign financial institution listed in Annex 1 to the Russia-related CAPTA Directive or otherwise determined to be subject to the prohibitions of the Russia-related CAPTA Directive, “or their property or interests in property,” which includes foreign financial institutions 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or more foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive.  As stated in the Russia-related CAPTA Directive, the prohibitions of this directive apply only with respect to a U.S. financial institution’s opening or maintaining of a correspondent account or payable-through account for or on behalf of, or processing of a transaction involving, a “foreign financial institution,” as defined in the Russia-related CAPTA Directive.  Thus, for purposes of the Russia-related CAPTA Directive, the prohibitions of this directive do not apply to non-“foreign financial institutions,” even if those non-“foreign financial institutions” are 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or more “foreign financial institutions” determined to be subject to this directive.

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Annex 1 to the Russia-related CAPTA Directive identifies Public Joint Stock Company Sberbank of Russia as well as many of its foreign financial institution subsidiaries.  The foreign financial institutions listed in Annex 1 have been determined to be subject to the prohibitions of the Russia-related CAPTA Directive for operating or having operated in the financial services sector of the Russian Federation economy, or for being foreign financial institutions that are 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or more foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive.  Please see FAQ 969 regarding the applicability of OFAC’s 50 Percent Rule to these entities.

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The Russia-related CAPTA Directive prohibits U.S. financial institutions from:  (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive; and (ii) the processing of transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive.  Please see the Russia-related CAPTA Directive for the definition of the terms “U.S. financial institution” and “foreign financial institution” for purposes of this directive.  Please see FAQ 969 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive.

Annex 1 to the Russia-related CAPTA Directive lists the foreign financial institutions determined to be subject to the prohibitions as of March 26, 2022.  Foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including the foreign financial institutions listed in Annex 1, can be found on the Office of Foreign Assets Control’s (OFAC) List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List).  Relevant entries on the CAPTA List will denote when a foreign financial institution became subject to the prohibitions of the Russia-related CAPTA Directive, as well as when the prohibitions of the Russia-related CAPTA Directive come into effect with respect to that foreign financial institution.

The below table identifies the dates the prohibitions of the Russia-related CAPTA Directive take effect for (i) foreign financial institutions listed in Annex 1 to the Russia-related CAPTA Directive, and (ii) foreign financial institutions otherwise determined to be subject to its prohibitions and added to the CAPTA List.  

Foreign Financial Institution Type Relevant Sanctions Effective Date
Foreign financial institutions listed in Annex 1 to the Russia-related CAPTA Directive 12:01 a.m. eastern daylight time on March 26, 2022
Foreign financial institution otherwise determined to be subject to the prohibitions of the Russia-related CAPTA Directive 12:01 a.m. eastern time on the date that is 30 days after the date of such determination

U.S. financial institutions must close any correspondent or payable-through account maintained for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, by the relevant effective date.  Separately, as of the relevant effective date, U.S. financial institutions may not process transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, and must reject such transactions unless exempt or authorized by OFAC.

Accordingly, after the relevant effective date, U.S. financial institutions must reject any transaction involving a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive or involving that foreign financial institution’s property or interests in property.  This includes rejecting transactions related to any securities (including depositary receipts) issued by a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including secondary market trading. For certain authorized securities-related transactions, see GL 9C and FAQ 981.  By virtue of the prohibition on the processing of transactions for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, U.S. financial institutions are also prohibited from engaging in transactions with a covered foreign financial institution in connection with the foreign financial institution’s role as a local custodian for depositary receipt issuances.

The Russia-related CAPTA Directive does not impose blocking sanctions and, thus, does not require U.S. financial institutions (or other U.S. persons) to block the assets of foreign financial institutions determined to be subject to the prohibitions of this directive.  However, U.S. persons should be aware that foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024  or E.O. 13662.

OFAC issued several Russia-related general licenses (GLs) authorizing certain transactions involving the foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive, including: 

  • GL 6B: authorizing transactions related to (1) the production, manufacturing, sale, or transport of agricultural commodities, agricultural equipment, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices; (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19); or (3) ongoing clinical trials and other medical research activities; 
  • GL 7A: authorizing overflight payments, emergency landings, and air ambulance services;
  • GL 8C: authorizing transactions related to energy; and
  • GL 27: authorizing transactions in support of nongovernmental organizations’ activities
     

On March 1, 2022, OFAC issued the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), which incorporate GL 5 in section 587.510 of the RuHSR.

For additional information, please see FAQs 976, 977, 978, 979981, 982 and 990.

Date Updated: July 14, 2022

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Treasury took expansive sanctions actions related to Russia’s financial services sector in February 2022 as detailed below.

  • Financial services sector determination.  On February 22, 2022, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination pursuant to E.O. 14024 that authorizes sanctions against persons determined to operate or to have operated in the financial services sector of the Russian Federation economy (see FAQ 964).  
  • Correspondent or payable-through account and payment processing prohibitions.  On February 24, 2022, the Office of Foreign Assets Control (OFAC) issued Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive), which prohibits U.S. financial institutions from:  (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive; and (ii) the processing of transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive.  Annex 1 to the Russia-related CAPTA Directive identifies Public Joint Stock Company Sberbank of Russia and other foreign financial institutions owned 50 percent or more by this bank as subject to these prohibitions, which become effective on March 26, 2022 (see FAQs 964, 967, 968, 969, 970, 971, 972 and 973).
  • Blocking certain Russian financial institutions.  OFAC designated specified Russian financial institutions pursuant to E.O. 14024, including the State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), VTB Bank Public Joint Stock Company, Public Joint Stock Company Bank Financial Corporation Otkritie, Promsvyazbank Public Joint Stock Company, Sovcombank Open Joint Stock Company, Joint Stock Commercial Bank Novikombank, and several of these financial institutions’ subsidiaries.  As a result, all property and interests in property of these entities in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked and must be reported to OFAC.  In addition, all property and interests in property of any entity that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.  Accordingly, U.S. persons, including U.S. financial institutions, are prohibited from transacting with these entities unless exempt or authorized by OFAC (see FAQs 974, 975, 976, 977, 978, 979, 980, 981, and 982).  
  • Expanding sovereign debt prohibitions to include the secondary market.  On February 22, 2022, OFAC issued Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), replacing and superseding Directive 1 under E.O. 14024 of April 15, 2021, to extend existing sovereign debt prohibitions to cover participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (see FAQs 888, 889, 890, 891, 965, and 983).  
  • New debt and equity restrictions involving certain Russia-related entities.  On February 24, 2022, OFAC imposed additional debt and equity restrictions involving Russia-related entities by issuing Directive 3 under E.O. 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive), to prohibit certain dealings by U.S. persons, or within the United States, in new debt of longer than 14 days maturity or new equity of Russia-related entities determined to be subject to the prohibitions of the Russia-related Entities Directive.  OFAC determined on February 24, 2022 that the entities listed in Annex 1 to the Russia-related Entities Directive, which include certain major Russian state-owned enterprises and large privately owned financial institutions, are subject to the prohibitions of this directive for new debt or equity issued on or after March 26, 2022 (see 983, 984, 985, 986, 987, 988 and 989). 
  • General Licenses (GLs).  OFAC issued several Russia-related GLs authorizing certain transactions otherwise prohibited by E.O. 14024 (see FAQs 974, 975, 976, 977, 978, 979981982, and 990).
  • New restrictions on sovereign transactions.  On February 28, 2022, OFAC issued Directive 4 under E.O. 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation” (Russia-related Sovereign Transactions Directive) to prohibit U.S. persons from engaging in any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities (see FAQs 998 – 1003).

Date Updated: March 02, 2022

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Directive 1 under E.O. 14024 of April 15, 2021 imposed prohibitions on participation in the primary market for ruble or non-ruble denominated bonds issued by, or the lending of ruble or non-ruble denominated funds to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.  The Russia-related Sovereign Debt Directive replaces and supersedes Directive 1 under E.O. 14024 of April 15, 2021.  It expands upon the existing prohibitions to also prohibit, as of March 1, 2022 , participation in the secondary market for ruble or non-ruble denominated bonds issued by these entities after March 1, 2022.  Please see FAQ 888 for additional details on the effective dates of these prohibitions.

The Russia-related Sovereign Debt Directive also includes technical revisions to the definition of “U.S. financial institution” to expand the definition.

Independent of the Russia-related Sovereign Debt Directive, OFAC has imposed prohibitions on certain Russia-related entities subject to the Russia-related Sovereign Debt Directive, pursuant to Russia-related directives under E.O. 13883 and E.O. 14024.

Date Updated: March 02, 2022

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Yes, cash shipments to Afghanistan may be authorized under General Licenses (GL) 14, GL 18GL 19, or GL 20  provided that they are ordinarily incident and necessary to effectuate the activities authorized by the GLs.  

As with all OFAC GLs, GLs 14, 18, 19, and 20 are “self-executing,” meaning that persons who determine that such activities are ordinarily incident and necessary to their authorized activities within the scope of the GLs may proceed without further assurances from OFAC.

Date Updated: February 25, 2022

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Yes.  Transactions that are ordinarily incident and necessary to give effect to the activities authorized in General Licenses (GL) 14, GL 15, GL 16, GL 17, GL 18, GL 19, or GL 20, including clearing, settlement, and transfers through, to, or otherwise involving privately owned and state-owned Afghan depository institutions, are authorized pursuant to these GLs. 

In addition, foreign financial institutions may engage in or facilitate transactions that would be authorized for U.S. persons under GLs 14, 15, 16, 17, 18, 19, or 20 without exposure to sanctions under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended.

Date Updated: February 25, 2022

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Yes.  Support to municipal water systems by NGOs for projects that directly benefit the Afghan people or otherwise relieve human suffering that would otherwise be prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, because of transactions with the Taliban and/or Haqqani Network would be covered by General Licenses (GLs) 14 and 19.  GL 18 authorizes all transactions and activities with the Taliban and/or Haqqani Network otherwise prohibited under the GTSR or FTOSR that are for the conduct of the official business of certain IOs.  Thus, if support to municipal water systems is part of these IOs’ official business, then it would not be prohibited. 

For example, this could include providing technical support to a project related to clean drinking water or making improvements to water systems for the benefit of the Afghan people. 

In addition, OFAC has issued Afghanistan-related GL 20, which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the GTSR, the FTOSR, or E.O. 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers support to municipal water systems by NGOs, IOs, or other persons.   

As noted in FAQ 996, the authorization in Afghanistan-related GL 20  may overlap with the authorizations in Afghanistan-related GLs 14, 18, and 19. Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 18, and 19.

Date Updated: February 25, 2022

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Yes.  Even to the extent doing so would involve transacting with the Taliban and/or Haqqani Network, NGOs can make salary support or stipend payments directly to healthcare workers, such as doctors at public hospitals or healthcare workers at community clinics, under General License (GL) 14 and GL 19.  Similarly, even to the extent doing so would involve transacting with the Taliban and/or Haqqani Network, NGOs can make such salary support or stipend payments directly to teachers, including teachers at Afghan public and private schools, under GL 19.  Under GL 18, certain IOs can provide such salary support payments directly to healthcare workers and teachers.  

In addition, OFAC has issued Afghanistan-related GL 20 , which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers salary support or stipend payments directly to teachers, including teachers at Afghan public and private schools, and healthcare workers by NGOs or other persons.   

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related GLs 14, 15, and 19.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 15, and 19.

Date Updated: February 25, 2022

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Yes.  Providing support to public hospitals, such as provision of health services, technical support, and institutional deliveries, as well as payments directly to healthcare workers, that would otherwise be prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, because of transactions with the Taliban and/or Haqqani Network are authorized under General Licenses (GLs) 14, 15, and 19

In addition, OFAC has issued Afghanistan-related GL 20 , which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the GTSR, the FTOSR, or E.O. 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers support to public hospitals in Afghanistan (e.g., health services, facilities maintenance, and health worker salaries) by NGOs or other persons.   

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related GLs 14, 15, and 19.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 15, and 19.

Date Updated: February 25, 2022

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As one example, if a non-governmental organization is providing support directly to Afghan hospitals or healthcare workers but needs to sign a memorandum of understanding that involves the Taliban in order to provide such support directly to the Afghan people, this engagement would be authorized under General Licenses (GLs) 14 and 19.

Other examples of engagement with the Taliban and the Haqqani Network that are authorized under GLs 14 and 19 if they are ordinarily incident and necessary to activities authorized by these GLs include: (i) general coordination on delivery and provision of humanitarian aid or shipments; (ii) administrative issues involving importation of goods; (iii) attendance at donor coordination meetings; (iv) sharing descriptions of projects; (v) coordination with regard to travel or project locations; (vi) participation in technical working groups; and (vii) sharing of office space.

In addition, payments of taxes, fees, or import duties to, or the purchase or receipt of permits, licenses, or public utility services from, the Taliban, the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest, are authorized under GLs 14 and 19, if ordinarily incident and necessary to activities authorized by the GLs.  

In addition, OFAC has issued Afghanistan-related GL 20 , which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers transactions involving the Taliban or the Haqqani Network that are authorized under GLs 14 and 19.  

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related GLs 14 and 19.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14 and 19. 

Date Updated: February 25, 2022

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Yes.  Both U.S. and non-U.S. companies can ship food to Afghanistan, and banks can process financial transfers and other transactions associated with food shipments to Afghanistan.

As described in FAQ 930, U.S. sanctions do not specifically prohibit the exportation or reexportation of agricultural commodities, medicine, and medical devices to Afghanistan.

OFAC has also issued Afghanistan-related General License (GL) 15, which authorizes U.S. persons to engage in all transactions that are ordinarily incident and necessary to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts, and components for medical devices, or software updates for medical devices to Afghanistan, as those terms are defined in GL 15, as well as to persons in third countries purchasing specifically for resale to Afghanistan, and that may involve the Taliban, the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest subject to certain conditions.  FAQ 931 provides further guidance that non-U.S. persons may engage in or facilitate transactions that would be authorized for U.S. persons under GL 15.

GL 15 also authorizes U.S. persons to engage in transactions or activities that are ordinarily incident and necessary to authorized exports or reexports, including the processing of financial transactions and related clearing and settlement involving privately-owned and state-owned banks in Afghanistan.  

In addition, OFAC has issued Afghanistan-related GL 20 , which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers shipments of food and agricultural products to Afghanistan and banks’ processing of these transactions.

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorization in Afghanistan-related GL 15.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorization in GL 15. 

Date Updated: February 25, 2022

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The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV. One effect of subsection 1(a)(iii) is to require authorization before U.S. persons may engage in certain transactions regarding any equity interest in an entity owned 50 percent or more by the GOV. Subsequent to the issuance of E.O. 13835, OFAC received inquiries about how and whether subsection 1(a)(iii) of E.O. 13835 could affect the ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond. OFAC issued General License (GL) 5 on July 19, 2018, which removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.

General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license. Since that date, OFAC has extended the delay in effectiveness several times. Most recently, OFAC issued General License 5M on October 18, 2023, which further delays the effectiveness of the authorization in GL 5 until January 18, 2024. Between October 24, 2019 and January 18, 2024 (the date the authorization in General License 5M becomes effective), there is no authorization in effect that licenses against subsection 1(a)(iii) of E.O. 13835 applicable to the holders of the PdVSA 2020 8.5 percent bond. As a result, during such period, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.

To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply. OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.

Date Updated: October 18, 2023

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In July 2017, the United Kingdom Financial Conduct Authority (FCA) announced the “future cessation and loss of representativeness” of the ICE Benchmark Administration’s 35 global reference rates, the LIBOR rates.  In light of the discontinuation of LIBOR as a benchmark reference rate, OFAC is issuing additional guidance.   

The Belarus, Russia, Ukraine-/Russia-related, and Venezuela-related sanctions programs prohibit U.S. persons from dealing in certain new debt of persons identified as subject to these prohibitions.  In FAQ 944 (Belarus), FAQ 986 (Russia-related)FAQ 371 (Ukraine-/Russia-related), and FAQ 511 (Venezuela-related), OFAC provides examples of new debt, such as “bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper” issued on or after various specified dates.  For more information on the effective dates and relevant debt maturities for each of these sanctions programs, please see FAQ 947 (Belarus), FAQ 984 (Russia-related)FAQ 370 (Ukraine-/Russia-related), and FAQ 553 (Venezuela-related).

For the Belarus, Russia, Ukraine-/Russia-related, and Venezuela-related sanctions programs, OFAC has indicated that certain changes to contractual terms of loans, contracts, or other agreements that were entered into prior to the effective date of the relevant sanctions prohibitions could convert pre-existing debt that was not subject to the sanctions prohibitions into new debt that is subject to the sanctions prohibitions.  (See FAQ 947 (Belarus), FAQs 987 and 989 (Russia-related) FAQ 394 (Ukraine-/Russia-related), and FAQ 553 (Venezuela-related).

Loans, contracts, or other agreements that use LIBOR as a reference rate that are modified to replace such benchmark reference rate will not be treated as new debt for OFAC sanctions purposes, so long as no other material terms of the loan, contract, or agreement are modified.

Date Updated: February 24, 2022

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Yes. GLs 14, 15, 16, 17, 1819and 20  help implement recently adopted United Nations Security Council Resolution (UNSCR) 2615 (2021), which authorizes humanitarian assistance and other activities that support basic human needs as those terms are understood by the UN Security Council, as well as the processing and payment of funds, other financial assets or economic resources, and the provision of goods and services necessary to ensure the timely delivery of such assistance or to support such activities.  Specifically, UNSCR 2615 was intended to cover activities contemplated in the United Nations’ Transitional Engagement Framework (TEF) for Afghanistan, such as providing life-saving assistance; sustaining essential services; and preserving social investments and community-level systems essential to meeting basic human needs.

These GLs do not relieve any person from compliance with other U.S. federal laws or requirements of other federal agencies, or from applicable international obligations.

Date Updated: February 25, 2022

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The purchases of fuel, payment for telecommunications services, payment for security services, payment of rent, and payment of utilities may be authorized under 14, 15, and 19 provided that they are ordinarily incident and necessary to effectuate the activities authorized by the GLs.  As with all OFAC GLs, GLs 14, 15, and 19 are “self-executing,” meaning that persons who determine that such activities are ordinarily incident and necessary to their authorized activity within the scope of the GL may proceed without further assurance from OFAC.  

OFAC has also issued Afghanistan-related GL 17 to authorize all transactions that are for the conduct of the official business of the United States Government by employees, grantees, or contractors and that involve the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.  OFAC also issued GL 18 to authorize all transactions that are for the conduct of official business by employees, grantees, or contractors of certain international organizations (IOs) and that involve the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.

In  addition, OFAC has issued Afghanistan-related GL 20, which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore covers purchases of fuel, payment for telecommunications services, payment for security services, payment of rent, and payment of utilities by NGOs or other persons.   

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related GLs 14, 15, and 19.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 15, and 19.  In all cases, authorized transactions and activities must comply with the terms and conditions set forth in GLs 14, 15, 17, 18, 19, and 20.  Notably, these GLs explicitly do not authorize financial transfers to the Taliban or the Haqqani Network, other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services related to the authorized activities as described in the respective GLs.  In addition, these GLs do not relieve any person from compliance with other U.S. federal laws or requirements of other federal agencies, or from applicable international obligations.

If individuals, entities, international organizations, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they can contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov.  Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490.  OFAC prioritizes license applications, compliance questions, and other requests that are related to humanitarian support.

Date Updated: February 25, 2022

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No.  U.S. sanctions on the Taliban and the Haqqani Network do not prohibit the movement of funds into or out of Afghanistan, provided that the transactions do not involve blocked individuals or entities, or property in which a blocked person has an interest.  

In addition, OFAC has issued General Licenses (GLs) 14, 15, 16, 17, 18, 19 and 20 under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), and Executive Order (E.O.) 13224, as amended.  For a consolidated list of all relevant General Licenses and FAQs, please see OFAC’s humanitarian Fact Sheet, “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People” (this content was updated on April 13, 2022), that provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. 

U.S. sanctions on the Taliban and the Haqqani Network do not prohibit — and GLs 14, 15, 16, 17, 18, 19, and 20 do not require — any particular method for moving or sending money into or out of Afghanistan.  When selecting a method of payment — including electronic transfer or hand carrying of funds — OFAC urges due diligence tailored to the particular sanctions risks to ensure that payments do not involve individuals or entities identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) or whose property and interests in property are otherwise blocked, unless exempt from regulation or authorized by OFAC.  For more information on OFAC due diligence expectations and compliance programs, please see FAQs 25, 27-31 and A Framework for OFAC Compliance Commitments.

Date Updated: February 25, 2022

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A number of members of the Taliban and/or the Haqqani Network are explicitly included on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List).  Persons operating in Afghanistan can use OFAC’s SDN List Search Tool to identify such members of the Taliban or the Haqqani Networks explicitly included on the SDN List, as well as other individuals or entities explicitly subject to U.S. sanctions.  For more information on using OFAC’s SDN List Search Tool and assessing OFAC Name Matches, please see OFAC FAQs 5, 82, 246-253, 287, 369, 467, and 892.  

OFAC would encourage any person operating in Afghanistan to use all information at their disposal when assessing their risk for sanctions exposure.  Supplementing internal due diligence information with an array of open-source material can be an effective compliance practice to aid in identifying risky counterparties involved in any in-country activity.  For more information on OFAC due diligence expectations and compliance programs, please see FAQs 25, 27-31 and A Framework for OFAC Compliance Commitments.

Date Updated: February 25, 2022

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No.  In contrast to sanctions programs administered and enforced by OFAC with regard to North Korea, Cuba, Iran, Syria, and the Crimea and so-called Donetsk People’s Republic and Luhansk People’s Republic regions  of Ukraine, there are no comprehensive sanctions on Afghanistan.  Therefore, there are no OFAC-administered sanctions that prohibit the export or reexport of goods or services to Afghanistan, moving or sending money into and out of Afghanistan, or activities in Afghanistan, provided that such transactions or activities do not involve sanctioned individuals, entities, or property in which sanctioned individuals and entities have an interest.

Certain Afghanistan-related individuals and entities are included on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), most notably the Taliban and the Haqqani Network.  The Taliban are designated as a Specially Designated Global Terrorist (SDGT) under Executive Order (E.O.) 13224.  The Haqqani Network is designated as an SDGT under E.O. 13224 and a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and Nationality Act.  Transactions or activities by U.S. persons that involve these entities are generally prohibited.  

In addition, OFAC has issued GLs 14, 15, 16, 17, 1819, and 20  under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), and E.O. 13224, as amended.  For a consolidated list of all relevant General Licenses and FAQs, please see OFAC’s humanitarian Fact Sheet, “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People,” (this content was updated on April 13, 2022) that provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. 

Date Updated: February 25, 2022

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No.  Non-U.S. persons may engage in or facilitate transactions that would be authorized for U.S. persons under Afghanistan-related GLs 14, 15, 16, 17, 1819 or 20without exposure to sanctions under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended. 

For example, activity that would be authorized by GLs 14, 15, 16, 17, 18, 19, or 20 if engaged in by a U.S. person would not be considered “significant” for the purposes of a secondary sanctions determination under E.O. 13224, as amended.  Accordingly, foreign financial institutions do not risk exposure to correspondent and payable-through account sanctions under E.O. 13224, as amended, if they knowingly conduct or facilitate a significant transaction on behalf of persons blocked under E.O. 13224, as amended, that would be authorized under GLs 14, 15, 16, 17, 18, 19, or 20 if engaged in by a U.S. person. 

For more information on relevant authorizations and guidance for providing humanitarian assistance to Afghanistan, please see OFAC’s humanitarian Fact Sheet, “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People,” (this content was updated on April 13, 2022) which provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. 

If individuals, entities, international organizations, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they can contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov.  Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490.  OFAC prioritizes license applications, compliance questions and other requests that are related to humanitarian support. 
Date Updated: February 25, 2022

 

 

 

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For the purposes of Afghanistan-related GL 14, humanitarian assistance includes the provision of relief services related to natural and man-made disasters, the provision of healthcare and health-related services, protection and assistance for vulnerable or displaced populations (including women, individuals with disabilities, the elderly, survivors of violence, those incarcerated or detained, and the drug dependent), operation of orphanages, the distribution of articles (such as food, clothing, and medicine) intended to be used to relieve human suffering in Afghanistan, and training or other services related to any of the foregoing activities.  Other activities that support basic human needs include activities to support non-commercial development projects in Afghanistan that primarily benefit poor or at-risk populations or otherwise relieve human suffering, including activities related to shelter and settlement assistance, food security, livelihoods support, water, sanitation, health, hygiene, and COVID-19-related assistance, among others, and training or other services related to any of the foregoing activities.  However, in all cases, authorized humanitarian assistance and other activities that support basic human needs in Afghanistan must not entail financial transfers to the Taliban, the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest, other than for the purpose of effecting the payment of taxes, fees, and import duties, or the purchase or receipt of permits, licenses, or public utility services described in GL 14 and FAQ 928.

In addition, OFAC has issued Afghanistan-related GL 20, which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers humanitarian assistance to Afghanistan or other activities that support basic human needs in Afghanistan.

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorization in Afghanistan-related GL 14.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorization in GL 14.

For more information on relevant authorizations and guidance for providing humanitarian assistance to Afghanistan, please see OFAC’s humanitarian Fact Sheet, “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People,” (this content was updated on April 13, 2022) which provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. If individuals, nongovernmental organizations, international organizations, companies, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they can contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov.  Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490.  OFAC prioritizes license applications, compliance questions and other requests that are related to humanitarian support.

Date Updated: February 25, 2022

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No.  The Taliban are designated as a Specially Designated Global Terrorist (SDGTs) under Executive Order (E.O.) 13224.  The Haqqani Network is designated as an SDGT under E.O. 13224 and a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and Nationality Act (INA).  These sanctions do not prohibit U.S. persons from exporting or reexporting goods or services to Afghanistan, provided that the transactions do not involve sanctioned individuals or entities, or property in which a blocked person has an interest unless exempt from regulation or authorized by OFAC.

In addition, OFAC has issued Afghanistan-related General Licenses (GLs) 14, 15, 16, 17, 1819, and 20 under the Global Terrorism Sanctions Regulations, 331 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), and E.O. 13224, as amended.  For a consolidated list of all relevant GLs and FAQs, please see OFAC’s humanitarian Fact Sheet, “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People,” (this content was updated on April 13, 2022) which provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. 

The GLs mentioned above do not authorize any debit to a blocked account on the books of a U.S. financial institution and restrict certain financial or other transfers to specified blocked persons, including the Taliban, the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest.  

For activity outside the scope of these GLs, OFAC may issue specific licenses on a case-by-case basis to authorize certain transactions involving U.S. persons or the U.S. financial system that may otherwise be prohibited by OFAC sanctions, provided those transactions are in the foreign policy interests of the United States.

If individuals, nongovernmental organizations, international organizations, companies, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they may contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov.  Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490.  OFAC prioritizes license applications, compliance questions and other requests that are related to humanitarian support.  

Date Updated: February 25, 2022

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No.  The Taliban are designated as a Specially Designated Global Terrorist (SDGT) Executive Order (E.O.) 13224, as amended.  The Haqqani Network is designated as an SDGT under E.O. 13224, as amended, and a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and Nationality Act (INA).  These sanctions do not prohibit U.S. persons from exporting or reexporting goods or services (including noncommercial, personal remittances) to Afghanistan, provided that the transactions do not involve sanctioned individuals or entities, or property in which a blocked person has an interest, unless exempt from regulation or authorized by OFAC.  For example, U.S. sanctions do not prohibit the hand-carrying of noncommercial, personal remittances to an individual in Afghanistan or ordinarily resident in Afghanistan, other than a blocked individual.

OFAC has also issued Afghanistan-related General License (GL) 16 to facilitate the transfer of noncommercial, personal remittances to individuals in Afghanistan.  GL 16 authorizes U.S. persons to engage in transactions that are ordinarily incident and necessary to the transfer of noncommercial, personal remittances, including through Afghan depository institutions, and that may involve the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, that are prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or E.O. 13224, as amended.

In addition, OFAC has issued Afghanistan-related GL 20, which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the GTSR, the FTOSR, or E.O. 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers the sending of personal remittances to Afghanistan.

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorization in Afghanistan-related GL 16.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GL 16.  However, GLs 16 and 20 do not authorize any debit to a blocked account of the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, on the books of a U.S. financial institution.  In addition, GLs 16 and 20 do not authorize financial transfers to the Taliban, the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, other than for the purpose of effecting the payment of reasonable and customary taxes, fees, or other duties as described in the respective GLs.  Transactions that are ordinarily incident and necessary to give effect to the activities authorized in GLs 16 and 20, including clearing, settlement, and transfers through, to, or otherwise involving privately-owned and state-owned Afghan depository institutions, are also authorized pursuant to GLs 16 and 20.  GL 20 also does not authorize transfers of luxury items or services to the Taliban, the Haqqani Network, any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, or any blocked individual who is in a leadership role of a governing institution in Afghanistan.  

For activity outside the scope of GLs 16 or 20, OFAC may issue specific licenses on a case-by-case basis to authorize certain transactions involving U.S. persons or the U.S. financial system that may otherwise be prohibited by OFAC sanctions, provided those transactions are in the foreign policy interests of the United States. 

Date Updated: February 25, 2022

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Yes.  Transactions by U.S. persons and within the United States involving derivative products whose value is linked to an underlying asset that constitutes prohibited debt issued by a person subject to Directive 1 under E.O. 14038 are prohibited, unless otherwise authorized by the Office of Foreign Assets Control.

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If a U.S. person entered into a revolving credit facility or long-term loan agreement prior to December 2, 2021, drawdowns and disbursements with repayment terms of 90 days or less are permitted.  In addition, drawdowns and disbursements whose repayment terms exceed 90 days are not prohibited if the terms of such drawdowns and disbursements (including the length of the repayment period, the interest rate applied to the drawdown, and the maximum drawdown amount) were contractually agreed to prior to December 2, 2021 and are not modified on or after December 2, 2021.  U.S. persons may not deal in a drawdown or disbursement initiated on or after December 2, 2021 with a repayment term that is greater than 90 days if the terms of the drawdown or disbursement were negotiated on or after December 2, 2021.  Such a newly negotiated drawdown or disbursement would constitute a prohibited extension of credit.

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Yes.  U.S. financial institutions may continue to maintain correspondent accounts and process U.S. dollar-clearing transactions for the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus, provided such activity is not otherwise prohibited pursuant to E.O. 14038, any Executive order issued pursuant to the national emergency declared in E.O. 13405, or any other sanctions program implemented by the Office of Foreign Assets Control.

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No.  Directive 1 under E.O. 14038 prohibits U.S. persons from engaging in only certain activities with the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus, as explained in FAQ 940

All other activities with the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus, or involving their property or interests in property, are permitted, provided such activities are not otherwise prohibited pursuant to E.O. 14038, any Executive order issued pursuant to the national emergency declared in E.O. 13405, or any other sanctions program implemented by the Office of Foreign Assets Control.

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The term debt includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers’ acceptances, discount notes or bills, or commercial paper.

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No.  The prohibitions in Directive 1 do not apply to any entity that is owned, directly or indirectly, 50 percent or more by the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus, whether individually or in the aggregate.

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No, so long as the terms of such debt (including the repayment period, the interest rate, and the amount) were contractually agreed to before December 2, 2021 and are not modified on or after December 2, 2021.

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Pursuant to Directive 1 under E .O. 14038, the following activities by U.S. persons or within the United States are prohibited, except to the extent provided by law or unless licensed or otherwise authorized by the Office of Foreign Assets Control:  all transactions in, provision of financing for, and other dealings in new debt with a maturity of greater than 90 days issued on or after December 2, 2021 by the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus.  These prohibitions apply to all denominations of debt.

Further, except to the extent otherwise provided by law or unless licensed or otherwise authorized by the Office of Foreign Assets Control, the following are also prohibited:  (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions contained in Directive 1 under E.O. 14038; and (2) any conspiracy formed to violate any of the prohibitions in Directive 1 under E.O. 14038.
 

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GL 5 authorizes, through 12:01a.m. eastern standard time, April 1, 2022, all transactions and activities prohibited by Executive Order (E.O.) 14038 that are ordinarily incident and necessary to the wind down of transactions involving Open Joint Stock Company Belarusian Potash Company (BPC) or Agrorozkvit LLC, or any entity in which BPC or Agrorozkvit LLC owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, including the wind down of such transactions in which Belaruskali OAO has a property interest (e.g., certain resale transactions by BPC or Agrorozkvit LLC of product sourced from Belaruskali OAO).  

However, GL 5 does not authorize direct transactions with Belaruskali OAO, and does not extend Belarus GL 4, which expires at 12:01 a.m. eastern standard time, December 8, 2021.  Please see FAQ 918 for further details on the scope of GL 4.  

GL 5 also does not authorize the entry into new purchase contracts, or the stockpiling of inventory, involving BPC or Agrorozkvit LLC, or any entity in which BPC or Agrorozkvit LLC owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, that are not ordinarily incident and necessary to the wind down of transactions.  
 

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GL 4 authorizes, through 12:01 a.m. eastern standard time, December 8, 2021, all transactions and activities prohibited by Executive Order (E.O.) 14038 that are ordinarily incident and necessary to the wind down of transactions involving Belaruskali OAO, or any entity in which Belaruskali OAO owns, directly or indirectly, a 50 percent or greater interest, subject to the terms of the license.  GL 4 does not authorize the entry into new purchase contracts, or the stockpiling of inventory, involving Belaruskali OAO, or any entity in which Belaruskali OAO owns, directly or indirectly, a 50 percent or greater interest, on or after August 9, 2021 that are not ordinarily incident and necessary to the wind down of transactions.  After the expiration of GL 4, unless exempt or authorized by OFAC, U.S. persons will be prohibited from engaging in transactions with Belaruskali OAO, or any entity in which Belaruskali OAO owns, directly or indirectly, a 50 percent or greater interest, and must block property or interests in property of such persons that are in, or come within, the United States, or the possession or control of a U.S. person. 

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The GL at § 542.516 of the SySR authorizes NGOs to engage in activities in support of certain non-commercial activities in Syria, including:  humanitarian projects to meet basic human needs; democracy-building; education; non-commercial development projects directly benefitting the Syrian people; the preservation and protection of cultural heritage sites; environmental and natural resource protection; and disarmament, demobilization, and reintegration (DDR) programs and peacebuilding, conflict prevention, and conflict resolution programs.  This includes early-recovery-related transactions and activities by NGOs in support of transactions and activities that fall within the categories listed above, including:

  • the provision of healthcare and health-related services (such as the restoration of health facilities; the distribution of medical equipment, supplies, and pharmaceuticals; and technical training for and supervision of healthcare workers); 
  • the provision of educational support and training services (such as the rehabilitation of local schools, the provision of training and equipment support to local educators, training and equipment support to local officials on the operations and management of critical infrastructure, and the provision of vocational and business management training); 
  • the provision of agricultural-related services (such as the refurbishment of mills, silos, and bakeries to improve food security; the provision of veterinary health services and pharmaceuticals to promote the health of livestock; and training and distribution of agricultural related items); and
  • activities related to shelter and settlement assistance, and clean water assistance (such as the rehabilitation and restoration of conflict-damaged water systems, sanitation, and hygiene infrastructure; supplying associated spare parts, training, and support for maintenance of equipment; and rehabilitation of irrigation pumps and canals). 

Additionally, organizations and entities may also rely on the authorization in § 542.533 for activities in certain economic sectors in non-regime held areas of Northeast and Northwest Syria.

For transactions and activities not otherwise authorized or exempt from sanctions, OFAC considers license requests on a case-by-case basis.  Individuals, NGOs, companies, or financial institutions with questions about engaging in or processing transactions or activities related to this authorization can contact OFAC’s Compliance Division. 

Updated: June 05, 2024

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No.  OFAC’s 50 Percent Rule does not apply to persons blocked solely pursuant to the blocking sanctions of E.O. 14046.  Unless an entity is itself a sanctioned person (as defined in E.O. 14046) and listed separately on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), it is not blocked.  For more information, please see FAQs 923 and 924

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No.  OFAC has implemented three authorizations and an exemption under Executive Order (E.O.) 14046 to ensure that humanitarian assistance can flow to the people of Ethiopia, Eritrea, and the greater Horn of Africa region.  These authorizations and exemption apply to all persons sanctioned under E.O. 14046, including Hidri Trust and RSTC.

Concurrent with the issuance of E.O. 14046, OFAC issued General Licenses (GLs) 1 and 2  to ensure that nongovernmental organizations (NGOs) and certain International Organizations (IOs) and other international entities, respectively, may continue to engage in and facilitate humanitarian-related transactions or activity to Ethiopia, Eritrea, or the greater Horn of Africa region.  OFAC also issued GL 3 , which authorizes U.S. persons to conduct all transactions and activities that are ordinarily incident and necessary to the exportation or reexportation of covered agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to Ethiopia or Eritrea, or to persons in third countries purchasing specifically for resale to Ethiopia or Eritrea.  Please see FAQs 925 (this content is no longer available) and 926, for additional information. 

E.O. 14046 also exempts the official business of the U.S. government by its employees, grantees, and contractors from the prohibitions, enabling continued support of development activity, life-saving humanitarian assistance, and longer-term assistance to address basic needs of at-risk populations in Ethiopia, Eritrea, or the greater Horn of Africa region.

As described in FAQ 927, non-U.S. persons, including NGOs and financial institutions, would not risk exposure to sanctions for engaging in certain humanitarian-related transactions or activity with Hidri Trust and RSTC that are otherwise exempt or authorized for U.S. persons, such as transactions involving the provision of certain humanitarian assistance or export of humanitarian goods to Ethiopia, Eritrea, or the greater Horn of Africa region.

In addition, OFAC issued GL 4 , “Authorizing the Wind Down of Transactions Involving Hidri Trust or Red Sea Trading Corporation.”  GL 4 authorizes, through 12:01 a.m. eastern standard time, December 14, 2021, subject to certain exceptions, all transactions and activities prohibited E.O. 14046 that are ordinarily incident and necessary to the wind down of transactions involving Hidri Trust or RSTC.  Transactions authorized by GLs 1, 2, or 3, including transactions related to the export or reexportation of covered agricultural commodities, medicine, medical devices, replacement parts and components, or software updates, will continue to be authorized even after the expiration of GL 4.
 

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Non-U.S. persons, including nongovernmental organizations and foreign financial institutions, generally do not risk exposure to U.S. sanctions for engaging in, or facilitating transactions or payments for, activities that would be exempt or authorized for U.S. persons pursuant to Ethiopia GL 1, GL 2, GL 3, or GL 4

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Yes.  The general license at § 542.513 of the Syrian Sanctions Regulations (SySR) authorizes, subject to certain conditions, the United Nations, including its Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations, The International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies; and The Global Fund to Fight AIDS, Tuberculosis, and Malaria, and Gavi, the Vaccine Alliance and their employees, contractors, or grantees to engage in all transactions and activities in support of their official business in Syria, including any stabilization and early recovery-related activities and transactions in support of their official business.  This authorization applies to all employees, grantees, and contractors carrying out the official business of the United Nations, its Specialized Agencies, Programmes, Funds, and Related Organizations, including nongovernmental organizations (NGOs) and private sector entities that are acting as grantees or contractors.  

In addition, § 542.211(d) and the general license at § 542.522 exempt and authorize, respectively, subject to certain conditions, the U.S. government and its employees, grantees, or contractors to engage in all transactions in support of their official business in Syria, including any stabilization and early recovery-related activities and transactions in support of their official business.  This exemption and authorization apply to all employees, grantees, and contractors carrying out the official business of the U.S. government, including NGOs and private sector entities that are acting as grantees or contractors.    

For NGOs that are not acting as grantees or contractors of the aforementioned international organizations or the U.S. government, please see the general license at § 542.516 for authorizations under the SySR related to certain transactions in support of certain NGO activities. 

Additionally, organizations and entities may also rely on the authorization in § 542.533 for activities in certain economic sectors in non-regime held areas of Northeast and Northwest Syria.

Separately, non-U.S. persons, including NGOs, private sector entities, and foreign financial institutions facilitating or assisting in the aforementioned activities, do not risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019 for engaging in the above activities for which a U.S. person would not require a specific license.  Please see 31 CFR § 542.414 and FAQ 884 for additional information.

Please note that this guidance does not apply to transactions and activities that may be subject to sanctions under other sanctions programs administered by OFAC (e.g., transactions with persons blocked under OFAC’s counterterrorism authority  (E.O. 13224, as amended) or OFAC’s Syria-related authority (E.O. 13894)), unless exempt or otherwise authorized by OFAC.

Updated: June 05, 2024 

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Once a U.S. person determines that they hold virtual currency that is required to be blocked pursuant to OFAC's regulations, the U.S. person must deny all parties access to that virtual currency, ensure that they comply with OFAC regulations related to the holding and reporting of blocked assets, and implement controls that align with a risk-based approach. (See 31 C.F.R. 501.603 for reporting requirements related to blocked and unblocked property.)

For example, a U.S. virtual currency company that maintains multiple virtual currency wallets in which a blocked person has an interest may choose to block each virtual currency wallet or opt to consolidate wallets that contain blocked virtual currency (similar to an omnibus account).  Each of these solutions is consistent with OFAC requirements for holding blocked property, so long as there are controls that will allow the virtual currency to be unblocked and returned to its owner only pursuant to an OFAC authorization or when the legal prohibition requiring the blocking of the virtual currency ceases to apply.  For those with questions about blocking funds related to traditional funds transfers, see FAQ 32.

U.S. persons are not obligated to convert the blocked virtual currency into traditional fiat currency (e.g., U.S. dollars), and are not required to hold such blocked property in an interest-bearing account.  Blocked virtual currency must be reported to OFAC within 10 business days, and thereafter on an annual basis, so long as the virtual currency remains blocked.  Questions about whether a transaction should be blocked may be directed to OFAC at 202-622-2490 or OFAC_Feedback@treasury.gov.  Owners of blocked virtual currency may also contact OFAC regarding the treatment of their virtual currency pursuant to this guidance.
 

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Digital currency includes sovereign cryptocurrency, virtual currency (non-fiat), and a digital representation of fiat currency.

A digital currency wallet is a software application (or other mechanism) that provides a means for holding, storing, and transferring digital currency. A wallet holds the user's digital currency addresses, which allow the user to receive digital currency, and private keys, which allow the user to transfer digital currency. The wallet also maintains the user’s digital currency balance. A wallet provider is a person (individual or entity) that provides the software to create and manage wallets, which users can download. A hosted wallet provider is a business that creates and stores a digital currency wallet on behalf of a customer. Most hosted wallets also offer exchange and payments services to facilitate participation in a digital currency system by users.

A digital currency address is an alphanumeric identifier that represents a potential destination for a digital currency transfer. A digital currency address is associated with a digital currency wallet.

Virtual currency is a digital representation of value that functions as (i) a medium of exchange; (ii) a unit of account; and/or (iii) a store of value; and is neither issued nor guaranteed by any jurisdiction.

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No.  The authorizations in paragraph (a) of Venezuela-related General Licenses (GLs) 7C (“Authorizing Certain Activities Involving PDV Holding, Inc. and CITGO Holding, Inc.”) and 20B (“Authorizing Official Activities of Certain International Organizations Involving the Government of Venezuela”), respectively, have not expired and remain in effect.  The activities described in paragraph (a) of GLs 7C and 20B, respectively, are authorized for an 18-month period, which renews automatically for an additional 18 months on the first day of each month, unless the respective GL is modified or revoked.

In the case of GL 7C, the authorization in paragraph (b), which relates to the purchase and importation of petroleum and petroleum products from Petróleos de Venezuela, S.A., expired on April 28, 2019.  The authorization in GL 7C paragraph (b) does not automatically renew and is no longer in effect.

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URGENT NOTE:  The U.S. Department of State cautions against any travel by U.S. persons to Iran.  The Department of State has issued a Level Four Travel Advisory (Do Not Travel) for Iran due to the risk of kidnapping, arbitrary arrest, and detention of U.S. citizens.  See additional guidance available at https://travel.state.gov/content/travel/en/traveladvisories/traveladvisories/iran-travel-advisory.html

Transactions ordinarily incident to travel to or from Iran by U.S. persons fall within an exemption under the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. part 560, and therefore generally are not prohibited.  See, e.g., 31 CFR. § 560.210(d).  Exempt transactions include religious pilgrimages by U.S. persons to the Imam Reza Holy Shrine and the acquisition of goods or services for personal use while traveling.  Furthermore, donations of articles, such as food, clothing, and medicine, by U.S. persons to the Imam Reza Holy Shrine intended to be used to alleviate human suffering also fall within an exemption and therefore generally are not prohibited under the ITSR.

However, U.S. persons may be prohibited from engaging in certain transactions involving persons blocked under sanctions programs or authorities outside the scope of the ITSR, such as Astan Quds Razavi (AQR) and its subsidiary, the Holy Shrine Organization, which oversees the Imam Reza Holy Shrine.  AQR was designated and added to OFAC’s Specially Designated Nationals and Blocked Persons List on January 13, 2021 pursuant to Executive Order (E.O.) 13876 for being owned or controlled by the Supreme Leader of Iran.  The Holy Shrine Organization is also considered blocked under E.O. 13876 pursuant to OFAC’s 50 Percent Rule to the extent it is 50 percent or more owned by AQR.  More information about OFAC’s 50 Percent Rule is available at https://ofac.treasury.gov/faqs/401.  U.S. persons are advised to act with caution when considering transactions or activities involving AQR or the Holy Shrine Organization. 

Those seeking additional guidance on transactions and activities involving the Imam Reza Holy Shrine may contact OFAC’s Sanctions Compliance and Evaluation Division by email at:  OFAC_Feedback@treasury.gov or may request a specific license or interpretive guidance from OFAC’s Licensing Division online at https://licensing.ofac.treas.gov/Apply/Introduction.aspx
 

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No.  The Taliban are designated as Specially Designated Global Terrorists (SDGTs) under Executive Order (E.O.) 13224, as amended.  The Haqqani Network is designated as an SDGT under E.O. 13224 and a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and Nationality Act (INA).  These sanctions do not prohibit U.S. persons from exporting or reexporting goods or services to Afghanistan, provided that the transactions do not involve other sanctioned individuals or entities, or property in which a blocked person has an interest unless exempt from regulation or authorized by OFAC.

OFAC has also issued Afghanistan-related General License No. 15 (GL 15) under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), and E.O. 13224, as amended.  GL 15 authorizes U.S. persons to engage in all transactions that are ordinarily incident and necessary to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts, and components for medical devices, or software updates for medical devices to Afghanistan, as those terms are defined in GL 15, as well as to persons in third countries purchasing specifically for resale to Afghanistan, and that may involve the Taliban, the Haqqani Network, or any entity in which Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest, subject to certain conditions.  GL 15 also authorizes U.S. persons to engage in transactions or activities that are ordinarily incident and necessary to authorized export or reexports, including the processing of financial transactions and related clearing and settlement involving banks in Afghanistan.  

In addition, OFAC has issued Afghanistan-related GL 20, which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the GTSR, the FTOSR, or E.O. 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers the exportation or reexportation of agricultural commodities, medicine, and medical devices to Afghanistan, as well as transactions ordinarily incident and necessary to such export or reexports.   

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorization in Afghanistan-related GL 15.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorization in GL 15.

However, GLs 15 and 20 do not authorize any debit to a blocked account on the books of a U.S. financial institution.  In addition, GLs 15 and 20 do not authorize financial transfers to the Taliban, the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest, other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services as described in the respective GLs.  For purposes of clarity, transfers of funds to or from Afghanistan that are ordinarily incident and necessary to give effect to the activities authorized in GLs 15 and 20, including clearing and settlement involving banks in Afghanistan, are authorized under GLs 15 and 20.  GL 20 also does not authorize transfers of luxury items or services to the Taliban, the Haqqani Network, any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, any blocked individual who is in a leadership role of a governing institution in Afghanistan.  GL 20 also does not authorize any transaction involving any other persons blocked pursuant to the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, outside of the entities and individuals mentioned above. 

Where not covered by GLs 15 and 20, or any other relevant authorizations issued by OFAC, OFAC may also issue specific licenses to authorize certain transactions involving U.S. persons or the U.S. financial system that may otherwise be prohibited by OFAC sanctions, provided those transactions are in the foreign policy interests of the United States.

If individuals, entities, companies, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they can contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov.  Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490. 

Date Updated: February 25, 2022

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Ethiopia GL 2 authorizes certain transactions and activities involving nongovernmental organizations’ (NGOs) activities in Ethiopia or Eritrea, including:  activities to support humanitarian projects and to meet basic human needs (such as, among other examples provided in GL 2, shelter and settlements assistance, water, sanitation, hygiene activities, and COVID-19 related assistance); activities to support democracy building (such as, among other examples provided in GL 2, activities to support conflict mitigation); activities to support education; activities to support non-commercial development projects directly benefiting the people of Ethiopia or Eritrea, including those related to health, food security, water and sanitation; and activities to support environmental and natural resource protection.  Please see GL 2 for details.

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No.  If a person is listed on OFAC’s Non-SDN Menu-Based Sanctions List (NS-MBS List) as subject to only one or more of the sanctions described in section 2(a)(i)(B) – (E) of E.O. of September 17, 2021, these non-blocking sanctions do not apply to an entity owned in whole or in part, individually or in the aggregate, directly or indirectly, by such sanctioned person, unless OFAC separately lists the entity on the NS-MBS List as subject to sanctions. 

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No.  Unless an entity is itself a sanctioned person (as defined in E.O. of September 17, 2021) and listed separately on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), it is not blocked pursuant to E.O. of September 17, 2021.  OFAC’s 50 Percent Rule does not apply to persons blocked solely pursuant to section 2(a)(i)(A) of E.O. of September 17, 2021.

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E.O. of September 17, 2021 provides for the imposition of menu-based sanctions on foreign persons determined by the Secretary of the Treasury, in consultation with the Secretary of State, to meet certain criteria under the order, including foreign persons determined to be responsible for or complicit in actions or policies that expand or extend the ongoing crisis in northern Ethiopia or obstruct a ceasefire or peace process.  Section 1(a) of E.O. of September 17, 2021 provides the complete list of criteria for designation under the order. 

Section 2(a) of E.O. of September 17, 2021 lists the menu of prohibitions that can be imposed by the Secretary of the Treasury, in consultation with the Secretary of State, on a foreign person designated under the order. 

The prohibitions that may be selected include, among other things:  (1) blocking sanctions on all property and interests in property of the “sanctioned person” (as defined in E.O. of September 17, 2021), except for any entities owned, in whole or in part, directly or indirectly, by one or more sanctioned persons (unless the entity is itself a sanctioned person and the blocking sanctions have been selected); (2) a prohibition on any United States person investing in or purchasing significant amounts of equity or debt instruments of the sanctioned person; (3) a prohibition on any United States financial institution making loans or providing credit to the sanctioned person; (4) a prohibition on any transactions in foreign exchange that are subject to the jurisdiction of the United States and in which the sanctioned person has any interest; and (5) any of the above sanctions on the principal executive officer or officers of the sanctioned person, or on persons performing similar functions and with similar authorities.  Persons blocked pursuant to section 2(a)(i)(A) of E.O. of September 17, 2021 will appear on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), while persons sanctioned pursuant to section 2(a)(i)(B) – (E) of E.O. of September 17, 2021 will appear on to the Non-SDN Menu-Based Sanctions List (NS-MBS List).

For the purposes of E.O. of September 17, 2021, the term “sanctioned person” means a foreign person (1) that has been determined by Secretary of the Treasury, in consultation with the Secretary of State, to meet any of the designation criteria described in section 1 of E.O. of September 17, 2021; and (2) for whom the Secretary of the Treasury, in consultation with the Secretary of State, has selected one or more of the sanctions set forth in Section 2(a) of E.O. of September 17, 2021 to impose on that foreign person.  Please see Section 7(f) of E.O. of September 17, 2021.

E.O. of September 17, 2021 is designed to impose costs on actors contributing to the conflict in northern Ethiopia while mitigating potential undue harm to the people of Ethiopia, including by exempting the official business of the U.S. government by its employees, grantees, and contractors from the prohibitions under E.O. of September 17, 2021, enabling their continued support of development activity, life-saving humanitarian assistance, and longer-term assistance to address basic needs of at-risk populations.
 

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General licenses issued under the Iranian Transactions and Sanctions Regulations (ITSR) authorize certain U.S. academic institutions and other U.S. persons to provide certain services and software to Iranian students.  These general licenses include:

  • General License G (GL G) authorizes accredited graduate and undergraduate degree-granting U.S. academic institutions, including their contractors, to export services to students located in Iran, or located outside of Iran but who are ordinarily resident in Iran (“Iranian students”), to sign up for and participate in certain undergraduate level online courses, notably:  (i) courses in the humanities, social sciences, law, or business that are the equivalent of courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business; and (ii) introductory undergraduate level science, technology, engineering, or mathematics courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business.  In addition, under 31 CFR § 560.405, certain transactions ordinarily incident to a licensed transaction are also authorized.  OFAC interprets 31 CFR § 560.405 to authorize certain transactions ordinarily incident to courses authorized by GL G, including the giving of assignments and testing and grading of Iranian students. 
  • Section 560.540 of the ITSR authorizes the exportation to Iran of certain services and software incident to the exchange of communications over the internet, such as instant messaging, chat and email, social networking, sharing of photos and movies, web browsing, blogging, social media platforms, collaboration platforms, video conferencing, e-gaming platforms, e-learning platforms, automated translation, web maps, and user authentication services, as well as certain cloud-based services.  OFAC interprets these authorizations to cover video conferencing software and related services, as well as educational technology software and related services, that allow students to view courses and course materials, complete tests and assignments, receive grades, participate in discussions, and other, similar course-related online activity, provided that the software meets the additional criteria of the applicable authorization.  For more guidance on 31 CFR § 560.540 of the ITSR, please see FAQs 338–348, 434–443, 1087–1089, and 1110.

To export services to Iranian students that fall outside of these authorizations, U.S. persons may apply for a specific license through the OFAC License Application Page

Please note that the general licenses summarized above do not authorize the exportation of goods (including software), services, or technology to the Government of Iran, except as authorized under 31 CFR § 560.540(a)(6), or to persons blocked under any authority administered by OFAC, including OFAC’s counterterrorism or counterproliferation authorities. 

Date Updated: May 16, 2024

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The Protecting Europe’s Energy Security Act of 2019, 22 U.S.C. 9526 note, as amended (PEESA), requires the imposition of sanctions with respect to the provision of vessels engaged in specified activities for the construction of certain Russian energy export pipelines, including the Nord Stream 2 pipeline project, the TurkStream pipeline project, or any project that is a successor to either such project.  E.O. of August 20, 2021, issued under the International Emergency Economic Powers Act (IEEPA), authorizes the Secretary of the Treasury and the Secretary of State to further implement those sanctions and directs agencies of the United States government to take all appropriate measures within their authority to ensure the full implementation of those sanctions.

Among other things, E.O. of August 20, 2021 enables Treasury to promulgate regulations and provides for blocking of PEESA-designated persons without the exception relating to the importation of goods in Section 7503(e) of PEESA.  All property and interests in property of persons designated pursuant to E.O. of August 20, 2021 that are or come within the United States or the possession or control of U.S. persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.  Additionally, entities owned 50 percent or more, individually or in the aggregate, directly or indirectly, by one or more blocked persons are also blocked. 

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The announced import restrictions related to the permanent importation of firearms and ammunition that are the growth, product, or manufacture of the Russian Federation will be implemented by the U.S. Department of Justice, Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).  OFAC has concurred with the Deputy Secretary of State’s determination pursuant to the CBW Act regarding the imposition of import restrictions, and with ATF’s implementation of the restrictions according to State Department guidance.  

For information about the sanctions announced by the State Department pursuant to the CBW Act on August 20, 2021, please see the relevant State Department press statement and Federal Register Notice.  For additional guidance regarding the import restrictions, please review the related Fact Sheet published by the State Department.

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The prohibitions announced by the State Department on August 20, 2021 related to U.S. bank loans have the same scope as those imposed by OFAC in August 2019 under the CBW Act Directive.  Please see FAQs 675678 for additional information.

Independent of the CBW Act Directive, OFAC has imposed prohibitions on certain Russia-related sovereign entities subject to the CBW Act Directive, pursuant to Russia-related directives under Executive Order (E.O.) 14024 (see FAQ 1000).

Date Updated: March 02, 2022

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Russia-related GL 1A authorizes U.S. persons to engage in certain transactions and activities otherwise prohibited by Executive Order (E.O.) of August 20, 2021, “Blocking Property with Respect to Certain Russian Energy Export Pipelines,” or the Protecting Europe’s Energy Security Act of 2019, 22 U.S.C. 9526 note, as amended (PEESA).  A prior version of Russia-related GL 1A was issued on May 21, 2021 (GL 1).  On August 20, 2021, GL 1 was amended and reissued as Russia-related GL 1A to ensure that the scope of activities authorized with respect to the Federal State Budgetary Institution Marine Rescue Service (MRS) includes E.O. of August 20, 2021.  Russia-related GL 1A replaces and supersedes GL 1 effective August 20, 2021.  Specifically, GL 1A authorizes U.S. persons to engage in transactions and activities involving MRS, or any entity in which MRS owns, directly or indirectly, a 50 percent or greater interest, that are not related to the construction of the Nord Stream 2 pipeline project, the TurkStream pipeline project, or any project that is a successor to either such project.  GL 1A does not, however, authorize any transactions or activities with any vessels identified on the Office of Foreign Assets Control’s List of Specially Designated Nationals and Blocked Persons (SDN List) as blocked property of MRS, including vessels identified as blocked property of any entity in which MRS owns, directly or indirectly, a 50 percent or greater interest.

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No.  E.O. of August 9, 2021 authorizes the imposition of blocking sanctions on persons operating in certain identified sectors of the Belarus economy, including the defense and related materiel sector, security sector, energy sector, potassium chloride (potash) sector, tobacco products sector, construction sector, transportation sector, or any other sector of the Belarus economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State.  The identification of a sector pursuant to E.O. of August 9, 2021 provides notice that persons operating in the identified sector risk exposure to sanctions; however, the identification of a sector does not automatically block all persons operating in that sector of the Belarus economy.  Only persons designated on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), and entities owned 50 percent or more, individually or in the aggregate, directly or indirectly, by one or more such persons, are subject to blocking sanctions.

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E.O. of August 9, 2021 expands the scope of the national emergency pertaining to Belarus declared in E.O. 13405, “Blocking Property of Certain Persons Undermining Democratic Processes or Institutions in Belarus,” to provide additional authorities under which sanctions may be imposed against individuals and entities related to the Belarusian regime’s harmful activities and longstanding abuses aimed at suppressing democracy and the exercise of human rights and fundamental freedoms in Belarus.  E.O. of August 9, 2021 also addresses national security threats posed by the Belarusian regime’s illicit and oppressive activities stemming from the August 9, 2020 fraudulent Belarusian presidential election and its aftermath, such as the elimination of political opposition and civil society organizations and the regime’s disruption and endangering of international civil air travel.

As a result of E.O. of August 9, 2021, all property and interests in property of persons designated pursuant to this E.O. that are or come within the United States or the possession or control of U.S. persons are blocked, and U.S. persons are generally prohibited from engaging in transactions involving such designated persons unless authorized by OFAC or otherwise exempt from regulation.  Additionally, any entities owned 50 percent or more, individually or in the aggregate, directly or indirectly, by one or more blocked persons are also blocked.

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For purposes of Venezuela GL 40, the term liquefied petroleum gas refers to the definition provided by the U.S. Energy Information Administration – a group of hydrocarbon gases, primarily propane, normal butane, and isobutane, derived from crude oil refining or natural gas processing. These gases may be marketed individually or mixed. They can be liquefied through pressurization (without requiring cryogenic refrigeration) for convenience of transportation or storage. The definition excludes ethane and olefins. 

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No. Non-U.S. persons would not risk exposure under U.S. sanctions for engaging in activities or facilitating transactions or payments for such activities that would be authorized for U.S. persons pursuant to Venezuela GL 40.

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No.  Belarus GL 3 does not authorize the exportation, reexportation, or provision of any goods, technology, or services to the Belarusian KGB or any other blocked person, except for the limited purposes of complying with rules and regulations administered by, and certain actions and investigations involving, the Belarusian KGB or requesting certain licenses or authorizations for the importation, distribution, or use of information technology products in Belarus.

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Belarus GL 3 authorizes transactions and activities with the State Security Committee of the Republic of Belarus (the Belarusian KGB) that are necessary and ordinarily incident to requesting, receiving, utilizing, paying for, or dealing in certain licenses and authorizations for the importation, distribution, or use of certain information technology products in Belarus.  It also authorizes transactions and activities necessary and ordinarily incident to compliance with rules and regulations administered by, and certain actions or investigations involving, the Belarusian KGB.

The GL was issued to ensure that U.S. persons engaging in certain business activities in Belarus that are not otherwise prohibited are not unduly impacted.  Belarus GL 3 only authorizes certain transactions and activities with the Belarusian KGB acting in its administrative capacity and does not authorize U.S. persons to engage in transactions and activities with the Belarusian KGB except for the limited purposes described above.

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No.  The prohibitions of E.O. 13959, as amended, apply only with respect to certain purchases or sales of publicly traded securities of entities listed on the NS-CMIC List.  E.O. 13959, as amended, does not prohibit activity with entities listed on the NS-CMIC List that is unrelated to such securities, such as the purchase or sale of goods or services.  E.O. 13959, as amended, also does not prohibit the purchase or sale of goods or services with respect to subsidiaries of such entities.

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Yes.  U.S. market makers, and non-U.S. market makers who employ U.S. persons, are permitted to engage in activities that are necessary to effect divestiture during the during the 365-day periods in which divestment transactions are permitted or that are not otherwise prohibited under E.O. 13959, as amended, including the conversion of American depositary receipts (ADRs) of a CMIC into underlying securities of the CMIC on the foreign exchange where the underlying securities are listed.  See FAQ 865 with respect to the permissibility of market intermediaries and other participants engaging in ancillary or intermediary activities that are necessary to effect divestiture of covered securities.

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For purposes of E.O. 13959, as amended, U.S. persons employed by non-U.S. entities are not prohibited from being involved in, or otherwise facilitating, purchases or sales related to a covered security on behalf of their non-U.S. employer, provided that such activity is in the ordinary course of their employment and the underlying purchase or sale would not otherwise violate E.O. 13959, as amended, (e.g., neither the purchase nor sale of the covered security is for the ultimate benefit of a U.S. person; neither the purchase or sale is a willful attempt to evade the prohibitions of E.O. 13959, as amended, etc.).  

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U.S. persons are not prohibited from providing investment advisory, investment management, or similar services to a non-U.S. person, including a foreign entity or foreign fund, in connection with the non-U.S. person’s purchase or sale of a covered security, provided that the underlying purchase or sale would not otherwise violate E.O. 13959, as amended.  For example, a U.S. individual acting as the fund manager for a non-U.S. investment fund, or a U.S. entity that is the investment adviser or investment manager for a non-U.S. investment fund, is not prohibited from advising on, authorizing, directing, or approving purchases or sales of covered securities by the non-U.S. investment fund, provided that the underlying purchase or sale would not otherwise violate E.O. 13959, as amended (e.g., neither the purchase nor sale of the covered security is for the ultimate benefit of a U.S. person, the purchase or sale is not a willful attempt to evade the prohibitions of E.O. 13959, as amended, etc.).  See FAQ 901 with respect to the due diligence expectations associated with determining whether a particular purchase or sale is permissible.  

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For purposes of assessing whether certain purchases or sales are permissible under E.O. 13959, as amended, U.S. persons — including financial institutions, registered broker-dealers in securities, securities exchanges, and other market intermediaries and participants — may rely upon the information available to them in the ordinary course of business. 

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Pursuant to E.O. 13959, as amended, OFAC expects to use its discretion to target, in particular, persons whose operations include or support, or have included or supported, (1) surveillance of persons by Chinese technology companies that occurs outside of the PRC; or (2) the development, marketing, sale, or export of Chinese surveillance technology that is, was, or can be used for surveillance of religious or ethnic minorities or to otherwise facilitate repression or serious human rights abuse.

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OFAC has published a list on its website containing the names of entities that are subject to the prohibitions of E.O. 13959, as amended, as the Non-SDN Chinese Military-Industrial Complex Companies List (the “NS-CMIC List”), along with additional identifying information where possible.  Effective June 3, 2021, the NS-CMIC List replaced and superseded in its entirety the Non-SDN Communist Chinese Military Companies List (NS-CCMC List), which has been deleted from OFAC’s website.  Only entities whose names exactly match the names of the entities on the NS-CMIC List are subject to the prohibitions in E.O. 13959, as amended.  OFAC will refer to entities listed on the NS-CMIC List as “Chinese Military-Industrial Complex Companies” or “CMICs.”

For any entity listed in the Annex to E.O. 13959, as amended, the prohibitions go into effect beginning at 12:01 a.m. eastern time on August 2, 2021.  For any entity not listed in the Annex to E.O. 13959, as amended, the prohibitions go into effect beginning at 12:01 a.m. eastern time on the date that is 60 days after the date the entity is listed on the NS-CMIC List.

Purchases or sales of publicly traded securities of CMICs listed in or pursuant to E.O. 13959, as amended, made solely to divest, in whole or in part, such securities by a U.S. person are permitted until 12:01 a.m. eastern time on the date that is 365 days after the date the entity is listed in the Annex to E.O. 13959, as amended, or added to the NS-CMIC List.
 

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E.O. of June 3, 2021 amends E.O. 13959 by replacing Sections 1 through 5 of E.O. 13959, as amended, and revokes E.O. 13974.  In particular, E.O. of June 3, 2021 amends E.O. 13959 to prohibit the purchase or sale by U.S. persons of any publicly traded securities, or any publicly traded securities that are derivative of such securities or are designed to provide investment exposure to such securities, of any person listed in the Annex to E.O. 13959, as amended by E.O. of June 3, 2021, or of any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, and, as appropriate, the Secretary of Defense:

  • (i) to operate or have operated in the defense and related materiel sector or the surveillance technology sector of the economy of the People’s Republic of China; or
  • (ii) to own or control, or to be owned or controlled by, directly or indirectly, a person who operates or has operated in any sector described in clause (i) above, or a person who is listed in the Annex to E.O. 13959, as amended by E.O. of June 3, 2021, or who has otherwise been determined to be subject to the prohibitions in Section 1(a) of E.O. 13959, as amended by E.O. of June 3, 2021.

To implement E.O. of June 3, 2021, OFAC has published a list on its website containing the names of entities identified in or pursuant to E.O. 13959, as amended by E.O. of June 3, 2021, titled the Non-SDN Chinese Military-Industrial Complex Companies List (the “NS-CMIC List”).  In addition, OFAC is removing and replacing all previously issued Frequently Asked Questions (FAQs) related to E.O. 13959, as amended.  OFAC will refer to E.O. 13959 as amended by E.O. of June 3, 2021 as “E.O. 13959, as amended.”
 

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Consistent with FAQ 865, which clarifies that market intermediaries and other participants may engage in ancillary or intermediary activities that are necessary to effect divestiture during the relevant wind-down periods or that are not otherwise prohibited under E.O. 13959, as amended, transactions and activities by securities exchanges operated by U.S. persons involving the purchase or sale of publicly traded securities (or any publicly traded securities that are derivative of such securities or are designed to provide investment exposure to such securities) of any entity listed on the Non-SDN Chinese Military-Industrial Complex Companies List (the “NS-CMIC List”) are not prohibited. 

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Yes.  Market intermediaries, including market makers, and other participants may engage in ancillary or intermediary activities that are necessary to effect divestiture during the relevant wind-down periods or that are not otherwise prohibited under E.O. 13959, as amended.  Purchases or sales by U.S. persons (including investors and intermediaries) involving investment funds that are seeking to divest during the relevant wind-down periods are permitted.  See FAQ 901 with respect to the due diligence expectations associated with determining whether a particular purchase or sale is permissible. 

 

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For purposes of E.O. 13959, as amended, activity by U.S. persons related to the following services are considered permissible, to the extent that such support services are not provided to U.S. persons in connection with prohibited purchases or sales: clearing, execution, settlement, custody, transfer agency, back-end services, as well as other such support services. 

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Yes.  Under E.O. 13959, as amended, any purchase or sale of publicly traded securities, or any publicly traded securities that are derivative of such securities or are designed to provide investment exposure to such securities, of any CMIC listed on the NS-CMIC List is prohibited, regardless of such securities' share of the underlying index fund, ETF, or derivative thereof.

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Examples of financial instruments covered by this provision include, but are not limited to, derivatives (e.g., futures, options, swaps), warrants, American depositary receipts (ADRs), global depositary receipts (GDRs), exchange-traded funds (ETFs), index funds, and mutual funds, to the extent such instruments also meet the definition of "publicly traded security" as defined in section 3(c) of E.O. 13959, as amended.

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For purposes of E.O. 13959, as amended, the term “publicly traded securities” includes any “security,” as defined in section 3(a)(10) of the Securities Exchange Act of 1934, Public Law 73–291 (as codified as amended at 15 U.S.C. 78c(a)(10)), denominated in any currency that trades on a securities exchange or through the method of trading that is commonly referred to as “over-the-counter,” in any jurisdiction.

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The prohibitions in E.O. 13959, as amended, apply to a subsidiary of a Chinese Military-Industrial Complex Company (CMIC) listed on the NS-CMIC List only if such subsidiary itself is publicly listed on the NS-CMIC List by Treasury pursuant to E.O. 13959, as amended, or identified in the Annex of E.O. 13959, as amended.  OFAC’s 50 percent rule does not apply to entities listed solely pursuant to E.O. 13959, as amended.  Accordingly, the prohibitions on any subsidiaries listed on the NS-CMIC List would go into effect beginning 12:01 a.m. eastern time on the date that is 60 days after such subsidiary is added to the NS-CMIC List.  

 

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Consistent with OFAC regulations, persons may seek to be removed from the Specially Designated Nationals and Blocked Persons List or Other OFAC Sanctions Lists.  For information concerning the process for seeking such removal, please refer to OFAC’s Filing a Petition for Removal from an OFAC List webpage, which references the delisting petition procedures set forth at 31 C.F.R. § 501.807.  The procedures set forth at 31 C.F.R. § 501.807 are available to any person seeking to be removed from any OFAC list, regardless of whether that person is a “blocked person” within the meaning of that rule.

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Yes, it is possible to query for digital currency addresses using OFAC’s Sanctions List Search tool. Users of the tool may search for digital currency addresses by inputting the hash value into the "ID #" field and then clicking "Search." The ID # field does not use fuzzy logic, so only exact matches will be returned when searching for digital currency addresses with the Sanctions List Search tool.

Alternatively, OFAC’s SDN List and other OFAC sanctions lists are available in a number of file formats and downloads, which can be used to identify and screen for listed digital currency addresses. Additional information on OFAC's list file formats and downloads, can be accessed by visiting the FAQ Topic titled "Information on list file formats and downloads."

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OFAC’s Sanctions List Search application has been available to the public since 2011. Over the years the tool’s userbase grew to a point where the original infrastructure and design for the application could not keep up with demand.  In late 2020, OFAC took steps to increase the tool’s efficiency to improve its performance.  

The primary update was the addition of a new algorithm to the tool’s fuzzy logic search functionality.  The upgraded application still utilizes the original Soundex and Jaro-Winkler algorithms in addition to the new algorithm (see this link for more information on the upgrade).  As a result of this update, users may see differences in search results when compared to an earlier version of the tool.  If users had previously tested Sanctions List Search in order to determine how the tool could assist in their due diligence, it is recommended that such testing be repeated on the current version of the tool. OFAC may continue to periodically update and/or make changes to the tool.  While OFAC has no immediate plans to further upgrade the application’s fuzzy logic functionality users should watch OFAC’s website for information about future upgrades. As such, users are to advised that they are using a free service at their own risk, and that best practice dictates each user performs baseline checks to see how updates/changes to the tool may affect search results.

For more information regarding how the tool works and calculates scores, please refer to FAQs 246, 247 and 249.  For more information on who may use the tool, please see FAQ 287.

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Sanctions List Search will first look for potential matches based on the first letter of  input search terms and by checking for matches at least 50% or more similar based on edit distance (edit distance is the minimum number of operations required to transform the input string of characters into the string that it is being compared to on the list). Sanctions List Search then uses two matching logic algorithms, and two matching logic techniques to calculate the score. The two algorithms are Jaro-Winkler, a string difference algorithm, and Soundex, a phonetic algorithm. The first technique involves using the Jaro-Winkler algorithm to compare the entire name string entered against full name strings of potential match entries on OFAC's sanctions lists. The second technique involves splitting the name string entered into multiple name parts (for example, John Doe would be split into two name parts). Each name part is then compared to name parts on all of OFAC's sanctions lists using the Jaro-Winkler and Soundex algorithms. The search calculates a score for each name part entered, and a composite score for all name parts entered. Sanctions List Search uses both techniques each time the search is run and returns the higher of the two scores in the Score column.

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The score field indicates the similarity between the name entered and resulting matches on one of OFAC's sanctions lists. It is calculated using two matching logic algorithms: one based upon phonetics, and a second based upon the similarity of the characters in the two strings. The slider bar defaults to a score of 100, which indicates an exact match.  Lower scores indicate potential matches.

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In addition to returning results that are exact matches (when the match threshold slider bar is set to 100%), Sanctions List Search can also provide a broader set of results using fuzzy logic. This logic uses character and string matching as well as phonetic matching. Only the name field of Sanctions List Search invokes fuzzy logic when the tool is run. The other fields on the tool use character matching logic. For more information on what a true sanctions list match is, see FAQ 5.  For more information on the slider bar, see FAQ 247.  

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No.  The prohibitions of the Russia-related Sovereign Debt Directive apply only to bonds issued by, or loans made to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.  The prohibitions of the Russia-related Sovereign Debt Directive do not apply to the property or interests in property of those three entities.

Date Updated: February 22, 2022

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Even prior to June 14, 2021, “U.S. banks” were prohibited from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign (including the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation), and from lending non-ruble denominated funds to the Russian sovereign pursuant to the Russia-related Directive under Executive Order 13883 (“CBW Act Directive”), which was issued on August 2, 2019 and went into effect on August 26, 2019.  However, the CBW Act Directive does not prohibit “U.S. banks” (as defined in the CBW Act Directive) from participating in the primary market for ruble denominated bonds issued by the Russian sovereign, or the lending of ruble denominated funds to the Russian sovereign.

Pursuant to Directive 1A under (E.O.) 14024 , “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), after June 14, 2021, U.S. financial institutions (as defined in the Russia-related Sovereign Debt Directive) are prohibited from participating in the primary market for ruble or non-ruble denominated bonds issued by, or the lending of ruble or non-ruble denominated funds to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, unless otherwise authorized by OFAC or exempt.  Pursuant to the Russia-related Sovereign Debt Directive, as of March 1, 2022, U.S. financial institutions are also prohibited from participating in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by these entities. 

Note that the prohibitions found in the CBW Act Directive remain in effect and are separate from the prohibitions of the Russia-related Sovereign Debt Directive, or other directives under E.O. 14024.  For more information on the CBW Act Directive, please see FAQs 673 - 678.

Date Updated: March 02, 2022

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Pursuant to the Russia-related Sovereign Debt Directive, the following activities by a U.S. financial institution are prohibited:

  1. As of June 14, 2021, participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; 
  2. As of June 14, 2021, lending ruble or non-ruble denominated funds to the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; and
  3. As of March 1, 2022, participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.

Further, except to the extent otherwise provided by law or unless authorized by OFAC or exempt, the following are also prohibited pursuant to the Russia-related Sovereign Debt Directive:  (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the Russia-related Sovereign Debt Directive; and (2) any conspiracy formed to violate any of the prohibitions of the Russia-related Sovereign Debt Directive. 

Independent of the Russia-related Sovereign Debt Directive, OFAC has imposed prohibitions on certain Russia-related entities subject to the Russia-related Sovereign Debt Directive, pursuant to Russia-related directives under Executive Order (E.O.) 13883 and E.O. 14024.

Date Updated: March 02, 2022

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Persons identified pursuant to E.O. 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy are not subject to prohibitions under E.O. 14024 unless those persons are also sanctioned pursuant to E.O. 14024.  For more information regarding Directive 3, please review applicable OFAC public guidance, such as FAQ 411.

E.O. 14024 provides for blocking sanctions on persons operating in the technology sector or the defense and related materiel sector of the Russian Federation economy, or any other sectors determined by the Secretary of the Treasury, in consultation with the Secretary of State.  The identification of a sector pursuant to E.O. 14024 provides notice that persons operating in the identified sector are exposed to sanctions risk; however, such identification does not automatically block all persons operating in the sector.  Only persons designated pursuant to E.O. 14024 for operating in the defense and related materiel sector of the Russian economy (or any other sector identified under the E.O.) are subject to blocking sanctions and will appear on the SDN List.

E.O. 14024, as amended by E.O. 14114, also authorizes the imposition of sanctions on foreign financial institutions that have conducted or facilitated certain transactions involving Russia’s military-industrial base.  See FAQs 1147, 1148, 1149, 1150 and 1151 for information. 

Date Updated: February 23, 2024

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E.O. 14024 establishes a new national emergency under which sanctions may be imposed against individuals and entities furthering specified harmful foreign activities of the Russian Federation.  This national emergency is separate from the national emergency relating to the crisis in Ukraine, declared in E.O. 13660 and further addressed in E.O.s 13661, 13662, 13685, and 13849.   E.O. 14024 addresses national security threats posed by specified harmful foreign activities of the Russian Federation, including:  its efforts to undermine the conduct of free and fair democratic elections and democratic institutions in the United States and its allies and partners; engaging in and facilitating malicious cyber-enabled activities against the United States and its allies and partners; fostering and using transnational corruption to influence foreign governments; pursuing extraterritorial activities targeting dissidents or journalists; undermining security in countries and regions important to United States national security; and violating well-established principles of international law, including respect for the territorial integrity of states. 

Like any other blocking Executive order, E.O. 14024 permits the United States to impose blocking and short-of-blocking sanctions.  The Office of Foreign Assets Control (OFAC) issued several directives under E.O. 14024 specifying certain prohibitions relating to persons determined to be subject to the applicable directive.  OFAC recommends reviewing the sanctions lists maintained by OFAC, including the Specially Designated Nationals and Blocked Persons List (SDN List), the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List), and the Non-SDN Menu-Based Sanctions List (NS-MBS List), to determine which sanctions are applicable.

On December 22, 2023, the President issued E.O. 14114, “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities,” which amended E.O. 14024 to further address the Russian Federation’s continued use of its military-industrial base to aid its effort to undermine security in countries and regions important to United States national security.  See FAQ 1147 for information on how E.O. 14114 amended E.O. 14024.

Date Updated: February 23, 2024

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The CBW Act Directive defines the term “U.S. banks.”  This definition is consistent with section 4(c) of Executive Order (E.O.) 13883, and with the definition of “U.S. financial institution” at 31 CFR § 544.311.  The CBW Act Directive defines the term “Russian sovereign” as any ministry, agency, or sovereign fund of the Russian Federation, including the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance of the Russian Federation.   This term does not include state-owned enterprises of the Russian Federation.

Independent of the CBW Act Directive, OFAC has imposed prohibitions on certain Russia-related sovereign entities subject to the CBW Act Directive, pursuant to Russia-related directives under E.O. 14024 (see FAQ 1000).

Date Updated: March 02, 2022

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Pursuant to Executive Order (E.O.). 13883, 31 CFR § 544.802, and the CBW Act, on August 2, 2019, OFAC issued a Russia-Related Directive (the “CBW Act Directive”), which prohibits U.S. banks from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign and also prohibits U.S. banks from lending non-ruble denominated funds to the Russian sovereign.  The prohibitions under the CBW Act Directive do not apply to bonds or loans denominated in rubles.  The prohibitions in the CBW Act Directive only apply to “U.S. banks,” as that term is defined in the CBW Act Directive and consistent with section 4(c) of E.O. 13883 and consistent with the definition of U.S. financial institution at 31 CFR § 544.311.  The CBW Act Directive includes a definition of the term “Russian sovereign.”  The CBW Act Directive is effective as of August 26, 2019.

Independent of the CBW Act Directive, OFAC has imposed additional prohibitions on certain Russia-related sovereign entities subject to the CBW Act Directive, pursuant to Russia-related directives under E.O. 14024 (see FAQ 1000).

Date Updated: March 02, 2022

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Following the chemical weapons attack in Salisbury, United Kingdom, the Department of State, acting under the CBW Act pursuant to authority delegated to the Secretary of State, made a determination on August 6, 2018 that the Government of the Russian Federation had used chemical weapons in violation of international law or had used lethal chemical weapons against its own nationals. Effective as of August 27, 2018, the United States imposed a first round of sanctions against Russia.  On November 6, 2018, the Department of State determined that the Government of the Russian Federation had failed to meet the conditions described in the CBW Act to avoid the imposition of a second round of sanctions, including failing to provide reliable assurances that it would not engage in future chemical weapons attacks.  On August 2, 2019, the Department of State selected three additional sanctions to impose on Russia pursuant to the CBW Act, specifically, the sanctions related to U.S. bank loans, opposition to multilateral development bank assistance, and further export restrictions administered by the Department of Commerce.

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E.O. 13883 delegates to the Secretary of the Treasury the implementation of the sanctions related to multilateral development bank assistance and to United States bank loans that are contained in the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991, as amended (“CBW Act”).  22 U.S.C. §5605(b)(2)(A)-(B).  E.O. 13883 also provides authority pursuant to the International Emergency Economic Powers Act to the Secretary of the Treasury to take certain actions to implement the sanctions related to bank loans.

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The national emergency declared with respect to the Government of Sudan in Executive Order (E.O.) 13067 of November 3, 1997 — as expanded upon in scope by subsequent E.O.s — remains in effect.  As detailed below, certain sanctions have been imposed and others have been lifted pursuant to that national emergency, in response to developments in Sudan. 

The following sanctions authorities are in effect with respect to Sudan:

  • E.O. 14098 of May 4, 2023, among other things, authorizes the imposition of sanctions on foreign persons to address the situation in Sudan following the military’s seizure of power in October 2021 and the outbreak of inter-service fighting in April 2023, and to support a transition to democracy and civilian transitional government in Sudan.
  • E.O. 13400 of April 26, 2006 imposes sanctions on individuals and entities in connection with the conflict in Darfur and, in part, implements sanctions with respect to that conflict adopted by the United Nations Security Council. 

The following sanctions authorities are no longer in effect with respect to Sudan:

  • Effective October 12, 2017, sections 1 and 2 of E.O. 13067 of November 3, 1997 and all of E.O. 13412 of October 13, 2006 were revoked, pursuant to E.O. 13761 of January 13, 2017, as amended by E.O. 13804 of July 11, 2017.  To reflect this revocation of authorities, OFAC removed the Sudanese Sanctions Regulations, 31 CFR part 538 (SSR) from the Code of Federal Regulations (CFR) on June 29, 2018.  U.S. persons are not broadly prohibited from engaging in transactions with respect to Sudan or the Government of Sudan that were previously prohibited solely by the SSR. In addition, following the revocation of sections 1 and 2 of E.O. 13067 and E.O. 13412, persons designated solely pursuant to the blocking authorities of E.O. 13067 or E.O. 13412 were removed from OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List).
  • The determination regarding Sudan as a State Sponsor of Terrorism was rescinded on December 14, 2020.  Accordingly, Sudan is no longer subject to prohibitions under the Terrorism List Governments Sanctions Regulations, 31 CFR part 596 (TLGSR), or section 906(a)(1) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (22 U.S.C. 7205)

Note that the revocation of the aforementioned sanctions authorities does not affect past, present, or future OFAC enforcement investigations or actions associated with any apparent violations of the SSR that occurred prior to October 12, 2017 or of the TLGSR prior to December 14, 2020. 

Date Updated: May 4, 2023

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Applicants should clearly enumerate in a table format all pertinent information related to their proposed transactions, including: a) Full names and addresses of all parties involved in the transactions and their roles, including financial institutions and any Iranian broker (identify company principals), purchasing agent (identify company principals), end-user(s) (full contact name), or other participants involved in the purchase of the proposed export items; and b) If applicable, the commodity classification numbers that are associated with the proposed export items.

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OFAC permits two format options for submitting TSRA license applications:  online or hard-copy, though we highly recommend the use of OFAC’s online application portal.  Applications submitted via mail must be accompanied by a cover letter that includes some essential information:  the purpose of the application and the applicant’s full contact information.  If either the cover letter or the pertinent information is missing, the application is considered incomplete and risks delay or rejection. 

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With respect to non-U.S. persons, OFAC will not consider transactions to be “significant” for the purpose of a sanctions determination under the Caesar Act if U.S. persons would not require a specific license from OFAC to participate in such a transaction.  See 31 CFR § 542.414.  Accordingly, non-U.S. persons, including NGOs and foreign financial institutions, would not risk exposure to sanctions under the Caesar Act for engaging in activity, or facilitating transactions and payments for such activity, that is authorized for U.S. persons under a general license (GL) issued pursuant to the SySR or exempt.

Section 7425 of the Caesar Act codifies, with some exceptions, the general license in § 542.516 of the SySR that authorizes certain services in support of NGOs.  Additionally, Section 7432 of the Caesar Act includes a humanitarian waiver for activities not otherwise covered by GL § 542.516 of the SySR.

Furthermore, non-U.S. persons do not risk exposure to sanctions pursuant to the Caesar Act for engaging in or facilitating transactions and activities authorized pursuant to the General License at § 542.533, or transactions that are ordinarily incident and necessary to give effect to the activities authorized in § 542.533, or any other general license issued pursuant to the SySR.

Please note that this guidance with respect to non-U.S. persons does not apply to transactions and activities that may be subject to sanctions under other sanctions programs administered by OFAC (e.g., transactions with blocked persons designated under Executive Order (E.O.) 13224, as amended (OFAC’s counterterrorism authority) or E.O. 13894 (OFAC’s Syria-related authority)), unless exempt or otherwise permitted by OFAC.

Updated: June 14, 2024

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Burma General License (GL) 4 authorizes, subject to certain conditions, all transactions and activities prohibited by Executive Order (E.O.) 14014, that are ordinarily incident and necessary to the wind down of transactions involving, directly or indirectly, Myanmar Economic Corporation Limited (MEC) or Myanma Economic Holdings Public Company Limited (MEHL), or any entity in which MEC or MEHL owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m., eastern daylight time, June 22, 2021.  Persons unable to wind down transactions prohibited by E.O. 14014 in which such blocked persons have an interest before that time are encouraged to seek formal guidance from OFAC.  

For the duration of GL 4, non-U.S. persons may wind down transactions involving, directly or indirectly, MEC or MEHL, or any entity in which MEC or MEHL owns, directly or indirectly, a 50 percent or greater interest, without exposure to sanctions under E.O. 14014, provided that such wind down activity is consistent with GL 4.  

While GL 4 is in effect, wind down transactions may be processed through the U.S. financial system or involve U.S. persons, as long as the transactions comply with the terms and conditions in GL 4.

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No. GL 1C does not authorize the export of any goods, technology, or services directly or indirectly to the Federal Security Service or any other blocked person, except for the limited purposes of complying with rules and regulations administered by, and certain actions and investigations involving, the Federal Security Service or requesting certain licenses or authorizations for the importation, distribution, or use of information technology products in the Russian Federation.

Date Updated: April 27, 2023

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GL 1C only authorizes certain transactions and activities with the Federal Security Service acting in its administrative and law enforcement capacities. The GL was issued in order to ensure that U.S. persons engaging in certain business activities in Russia that are not otherwise prohibited are not unduly impacted. All other transactions and activities involving any property subject to U.S. jurisdiction or within the possession or control of U.S. persons in which the Federal Security Service has an interest, including all other transactions and activities directly or indirectly with the Federal Security Service, remain prohibited unless exempt or otherwise authorized by OFAC.

Date Updated: April 27, 2023

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GL 1C authorizes transactions with the Federal Security Service (a.k.a. Federalnaya Sluzhba Bezopasnosti) (a.k.a. FSB) that are ordinarily incident and necessary to requesting, receiving, utilizing, paying for, or dealing in certain licenses and authorizations for the importation, distribution, or use of certain information technology products in the Russian Federation.  It also authorizes transactions ordinarily incident and necessary to compliance with rules and regulations administered by, and certain actions or investigations involving, the Federal Security Service.

This general license does not authorize U.S. persons to engage in transactions with the Federal Security Service, except for the limited purposes described above, nor does it authorize the exportation, reexportation, sale or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any goods, services, or technology to the so-called “Donetsk People’s Republic” or “Luhansk People’s Republic” (DNR/LNR) regions of Ukraine, or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, pursuant to Executive Order 14065, or to the Crimea region of Ukraine.

Date Updated: April 27, 2023

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With respect to a person on the NS-MBS List subject to section 235(a)(3) of CAATSA, as implemented by section 1(a)(i) of Executive Order (E.O.) 13849, U.S. financial institutions are prohibited from making loans or providing credits to the identified person totaling more than $10,000,000 in any 12-month period, unless the person is engaged in activities to relieve human suffering and the loans or credits are provided for such activities.  This is not a blocking sanction, but rather a limit on the total amount of loans or credits that can be provided to the identified person within the specified time period by a U.S. financial institution, excluding loans or credit provided to such identified person for activities to relieve human suffering.  

Each U.S. financial institution must limit its provision of loans or credits to the identified person to $10,000,000 in any 12-month period, regardless of whether part or all the loans or credits in question has been repaid during the period.  This sanction is not a limit on the total loans or credits from all United States financial institutions collectively in the specific time period, but rather an institution-by-institution limit.

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No.  If a person is listed on OFAC’s Non-SDN Menu-Based Sanctions List (NS-MBS List) as subject to only a combination of the sanctions described in section 235(a)(1-8) and (10-11) of CAATSA, as implemented by Executive Order (E.O.) 13849, these non-blocking sanctions do not apply to an entity owned 50 percent or more, individually or in the aggregate, directly or indirectly, by such sanctioned person or persons, unless OFAC separately lists the owned entity on the NS-MBS List as subject to the same sanctions.  

However, section 235(a)(9) of CAATSA, as implemented by section 1(a)(iv) of E.O. 13849, blocks the property and interests in property of the sanctioned person, and a person subject to that sanction will be added to OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List).  The property and interests in property of persons on the SDN List are blocked, and any entity owned 50 percent or more, individually or in the aggregate, directly or indirectly, by blocked persons is itself blocked, as described in OFAC’s 50 Percent Rule.  

Individuals sanctioned under section 235(a)(12) of CAATSA (Sanctions on Principal Executive Officers), as implemented by section 1(a)(vi) of E.O. 13849, may be subject to any of the sanctions described in section 235(a).  To the extent that the sanctions selected are solely non-blocking sanctions, such person will be listed on the NS-MBS List.  Conversely, if the sanctioned individual is subject to the sanction described in section 235(a)(9), the individual is blocked and placed on the SDN List, and the 50 Percent Rule applies.

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For purposes of section 10(a)(2)(A) of SSIDES and § 589.201(a)(6)(vii)(B)(1) of the URSR, OFAC will interpret the phrase “subject to sanctions imposed by the United States with respect to the Russian Federation” to be persons subject to sanctions under SSIDES, as amended, the Ukraine Freedom Support Act (UFSA), as amended, provisions of CAATSA with respect to the Russian Federation, and any covered Executive order as defined in § 589.305 and section 10(f)(1) of SSIDES.  Section 10(f)(1) of SSIDES and § 589.305 define the term “covered executive order” to mean any of the following:   Executive Order (E.O.) 13660E.O. 13661E.O. 13662, E.O. 13685, E.O. 13694, relating to the Russian Federation, or E.O. 13757, relating to the Russian Federation.  Persons “subject to sanctions imposed by the United States with respect to the Russian Federation” includes persons who are listed on the SDN List, SSI List, or NS-MBS List pursuant to the authorities listed above, and associated persons subject to sanctions pursuant to OFAC’s 50 percent rule.

Date Updated: April 29, 2022

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“foreign person” – As stated in § 589.317 of the Ukraine-/Russia-Related Sanctions Regulations (URSR), the term foreign person for purposes of the SSIDES section 10 provisions in §§ 589.201(a)(6) and 589.413 means any citizen or national of a foreign state (including any such individual who is also a citizen or national of the United States), or any entity not organized solely under the laws of the United States or existing solely in the United States, but does not include a foreign state.  This definition is consistent with section 10(f)(2) of SSIDES.

“knowingly” – section 589.322 states that 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.  This definition is consistent with section 221(4) of CAATSA.

“materially violate” – For purposes of section 10(a)(1) of SSIDES, OFAC will interpret the term “materially violate” to refer to an “egregious” violation.  A determination about whether a violation is egregious will be based on an analysis of the applicable General Factors as described in OFAC’s Economic Sanctions Enforcement Guidelines, located in subsection (B)(1), section V of Appendix A to 31 C.F.R. part 501.

“facilitate[ion] . . . for or on behalf of” – For purposes of section 10(a)(2) of SSIDES, facilitating a significant transaction for or on behalf of a person will be interpreted to mean providing assistance for a transaction from which the person in question derives a particular benefit of any kind (as opposed to a generalized benefit conferred upon undifferentiated persons in aggregate).  Assistance may include the provision or transmission of currency, financial instruments, securities, or any other value; purchasing, selling, transporting, swapping, brokering, financing, approving, or guaranteeing; the provision of other services of any kind; the provision of personnel; or the provision of software, technology, or goods of any kind.

“significant transaction” – section 589.413 states that for purposes of the SSIDES prohibitions in § 589.201(a)(6)(vii), the Secretary of the Treasury or the Secretary’s designee will consider the totality of the facts and circumstances when determining whether transactions are “significant.”  As a general matter, some or all of the following factors may be considered: (1) the size, number, and frequency of the transaction(s); (2) the nature of the transaction(s); (3) the level of awareness of management and whether the transaction(s) are part of a pattern of conduct; (4) the nexus between the transaction(s) and the person subject to sanctions imposed by the United States with respect to the Russian Federation, as defined in SSIDES, or any child, spouse, parent, or sibling of such an individual; (5) the impact of the transaction(s) on the objectives of the Ukraine Freedom Support Act, SSIDES, CAATSA, Executive Order (E.O.) 13660, E.O. 13661, E.O. 13662, E.O. 13685, or any other Executive order issued pursuant to the national emergency declared in E.O. 13660; (6) whether the transaction(s) involve deceptive practices; and (7) such other factors that the Secretary of the Treasury or the Secretary’s designee deems relevant on a case-by-case basis.  

Furthermore, § 589.413(i) states a transaction is not significant if U.S. persons would not require specific licenses from OFAC to participate in it.  A transaction in which the person subject to sanctions is identified on the Sectoral Sanctions Identifications (SSI) List or the Non-SDN Menu-Based Sanctions (NS-MBS) List will only be potentially considered significant if:  1) the transaction involves deceptive practices (i.e., attempts to obscure or conceal the actual parties or true nature of the transaction(s), or to evade sanctions); and 2) such person is “subject to sanctions imposed by the United States with respect to the Russian Federation” or a child, spouse, parent, or sibling of such an individual, as described in § 589.413(d)(1) (see also FAQ 546).  

A transaction involving an entity solely on the SSI List or NS-MBS List is not automatically significant simply because a U.S. person would require a specific license from OFAC to participate in it and it involves deceptive practices.  In all cases, the totality of the circumstances, including the other factors listed above, will shape the final determination of significance.

“Deceptive or structured transaction” – the term structured, with respect to a transaction, has the meaning given the term “structure” in 31 CFR 1010.100 (xx) (or any corresponding similar regulation or ruling).  See 31 C.F.R. § 589.336.

Structured transactions are a type of deceptive transaction.  A “deceptive transaction” is one that involves deceptive practices.  As described in 31 C.F.R. § 589.413(f), “deceptive practices” are attempts to obscure or conceal the actual parties or true nature of a transaction, or to evade sanctions. 

Date Updated: April 29, 2022

 

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The United States stands with the Venezuelan people and the IV National Assembly in opposition to the Maduro regime. On January 09, 2023, OFAC issued Venezuela-related General License 31B authorizing all transactions involving the IV National Assembly, its Delegated Commission, any entity established by, or under the direction of, the IV National Assembly to exercise its mandate (“IV National Assembly Entity”), or involving any person appointed or designated by, or whose appointment or designation is retained by, the IV National Assembly, its Delegated Commission, or a IV National Assembly Entity, to act on behalf of the Government of Venezuela, including their respective members and staff, that are otherwise prohibited by E.O. 13884. The authorization also covers transactions prohibited by E.O. 13850, as amended, with respect to any person appointed or designated by, or whose appointment or designation is retained by, the IV National Assembly, its Delegated Commission, or a IV National Assembly Entity to the board of directors (including any ad hoc board of directors) or as an executive officer of a Government of Venezuela entity (including entities owned or controlled, directly or indirectly, by the Government of Venezuela). 

Effective January 09, 2023, General License 31B replaced and superseded General License 31A in its entirety.

Date Updated: January 09, 2023

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As described in FAQ 867, non-U.S. persons would not risk exposure to sanctions for engaging in humanitarian-related transactions or activity with Polymedics LLC and Letia Company that are exempt from regulation or authorized for U.S. persons by a general license in the Syrian Sanctions Regulations (SySR), 31 C.F.R. Part 542, such as transactions involving the provision of humanitarian assistance or export of humanitarian goods to Syria.  

Additionally, the Caesar Syria Civilian Protection Act of 2019 (Caesar Act) codifies, with some exceptions, the general license in § 542.516 of the SySR, which authorizes certain services in support of nongovernmental organizations and includes a humanitarian waiver. 

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Yes.  The identification of the CBoS on the SDN List does not trigger new prohibitions; existing general and specific licenses under the Syrian Sanctions Regulations (SySR), 31 C.F.R. Part 542, continue to apply as they did previously.  U.S. persons may continue engaging with the CBoS in connection with humanitarian assistance and certain other trade with Syria authorized by the SySR or exempt from regulation, including:  § 542.510 (Exports or reexports to Syria of items licensed or otherwise authorized by the Department of Commerce authorized; exports or reexports of certain services authorized); § 542.513 (Official business of certain international organizations and entities); § 542.516 (Certain transactions in support of nongovernmental organizations’ activities); and § 542.525 (Exportation or reexportation of services to Syria related to the exportation or reexportation of certain non-U.S.-origin goods authorized).  Of note, the export of U.S.-origin food and most medicines to Syria is not prohibited and does not require a Commerce or OFAC license (see 31 CFR § 542.510 and Syria FAQ 229), and U.S. persons can continue engaging with the CBoS in connection with these transactions.  Furthermore, § 542.404 of the SySR authorizes transactions ordinarily incident and necessary to a licensed transaction, with certain exceptions.

In addition, OFAC may issue specific licenses to authorize certain transactions involving U.S. persons or the U.S. financial system that may otherwise be prohibited by OFAC sanctions, provided those transactions are in the foreign policy interests of the United States.  OFAC has a longstanding licensing policy supporting the provision of humanitarian assistance

With respect to non-U.S. persons, OFAC will not consider transactions to be “significant” for the purpose of a sanctions determination under the Caesar Syria Civilian Protection Act of 2019 (Caesar Act) if U.S. persons would not require a specific license from OFAC to participate in such a transaction.  See 31 CFR § 542.414.  Accordingly, non-U.S. persons would not risk exposure to sanctions under the Caesar Act for engaging in activity with the CBoS that is authorized for U.S. persons under a general license in the SySR, such as transactions involving the provision of humanitarian assistance or export of humanitarian goods to Syria.  Further, the Caesar Act codifies, with some exceptions, the general license in § 542.516 of the SySR, as in effect the day before enactment of the Caesar Act, that authorizes certain services in support of nongovernmental organizations, and includes a humanitarian waiver.  

OFAC remains committed to ensuring that humanitarian assistance can flow to the people of Syria.  Treasury continues to support the critical work of governments, certain international organizations and entities, non-governmental organizations, and individuals delivering food, medicine, medical supplies, and humanitarian assistance to civilians in Syria.  If individuals, companies, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they can contact OFAC’s Compliance Division. 

Updated: June 14, 2024

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The Central Bank of Syria (CBoS) is blocked as part of the Government of Syria, as defined in E.O. 13582 of August 17, 2011 and the Syrian Sanctions Regulations (SySR), 31 C.F.R. Part 542.  On December 22, 2020, OFAC identified the CBoS on the Specially Designated Nationals and Blocked Persons List (SDN List), further underscoring its blocked status.  This identification does not trigger new prohibitions on the CBoS.  All property and interests in property of the CBoS remain blocked.  

Among other things, the SySR generally prohibit U.S. persons, unless exempt or authorized, from engaging in any transaction or dealing in property and interests in property of certain blocked persons, including the CBoS.  This also includes the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked, again including the CBoS.  The SySR also prohibit the export, reexport, sale, and supply of services to Syria (unless exempt or authorized), which would include services involving the CBoS in Syria.  

Pursuant to the Caesar Syria Civilian Protection Act of 2019, non-U.S. persons who knowingly provide significant financial, material, or technological support to, or knowingly engage in a significant transaction with the Government of Syria, including the CBoS, or certain other persons sanctioned with respect to Syria, risk exposure to sanctions. 

General and specific licenses under the SySR applicable to the CBoS continue to apply, including authorizations for the provision of humanitarian assistance and certain trade to Syria that may involve the CBoS.  For more information regarding authorizations for humanitarian assistance and other trade with Syria by U.S. and non-U.S. persons, please see FAQ 867

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Transactions and activities involving Iranian financial institutions blocked under E.O. 13902 remain authorized under General License (GL) L to the extent they are authorized, exempt, or otherwise not prohibited by the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). This authorization includes certain transactions and activities relating to the initiation and conduct of legal proceedings authorized or otherwise permitted pursuant to section 560.510 or 560.525 of the ITSR, such as transactions or activities related to the defense of individuals in legal proceedings in Iran brought by the Government of Iran, including any arrest, investigation, prosecution, or detention. Such permissible transactions and activities may include reasonable and customary payments for the provision of legal services, bail and/or bond payments, judicial costs and fees, costs for the production of documents and appearances of witnesses, and payment of experts.  

In addition, for purposes of secondary sanctions, as described in FAQ 844, non-U.S. persons are not exposed to sanctions for engaging in transactions and activities involving the Iranian financial sector or an Iranian FI blocked pursuant to E.O. 13902 that would be authorized for U.S. persons under GL L.  

Please note that, unless permitted by GL L and FAQ 844, payments made to Iran involving blocked Iranian persons — including the Government of Iran, including any political subdivision, agency, or instrumentality thereof — in connection with awards, orders, decisions, or settlement of claims may be subject to sanctions. OFAC will assess such transactions on a case-by-case basis.

Please also note that guidance above applies only with respect to transactions or activities involving Iranian FIs sanctioned solely pursuant to E.O. 13599 and E.O. 13902 or the Iranian financial sector.  These transactions and activities should not involve persons designated on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction (WMD) unless exempt or otherwise