Frequently Asked Questions

1148. What activities could expose a foreign financial institution (FFI) to sanctions under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?

1148 … 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… Read more

1149. What sanctions can be imposed on a foreign financial institution (FFI) that engaged in conduct described in section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114? What are the obligations of U.S. financial institutions?

1149 … 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… Read more

1150. What does determination of December 22, 2023, “Determination Pursuant to Section 11(a)(ii) of Executive Order (E.O. 14024)” (Russia Critical Items Determination) do?

1150 … 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… Read more

1151. How does OFAC intend to interpret the following terms in Executive Order (E.O.) 14024, as amended by E.O. 14114: “foreign financial institution,” “Russia’s military-industrial base,” and “significant transaction or transactions”?

1151 … 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… Read more

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

1152 … 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… Read more

1181. Effective June 12, 2024, how is Treasury interpreting Russia’s military-industrial base under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?

1181 … 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… Read more

1182. Are foreign financial institutions (FFIs) subject to sanctions risk for providing all financial services involving persons blocked pursuant to Executive Order (E.O.) 14024, as amended? What about agricultural, medical, and other transactions authorized by OFAC General Licenses?

1182 … 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… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence