Frequently Asked Questions

1005. Does 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), prohibit trading in the secondary markets for Russian sovereign debt?

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, “… Read more

1006. What does Executive Order (E.O.) 14065 do?

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 “… Read more

1007. Are U.S. persons authorized to engage in certain activity with 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")?

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)… Read more

1008. Is there a wind-down period for the prohibitions imposed in Executive Order (E.O.) 14065?

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)… Read more

1009. Does Executive Order (E.O.) 14065 block the entire Donetsk and Luhansk oblasts?

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… Read more

1010. My company transports Russian oil for sale to the United States and third countries. Can I continue to transport or sell Russian-origin oil without violating sanctions pursuant to Executive Order (E.O.) 14024?

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.… Read more

1189. What additional authorizations did Treasury issue on August 23, 2024 with respect to certain diamonds and diamond jewelry prohibited by Executive Order (E.O.) 14068?

Treasury issued two general licenses (GLs), GL 103 and GL 104, authorizing certain transactions with respect to certain diamonds and diamond jewelry that would otherwise be prohibited by E.O. 14068 in “Prohibitions Related to Imports of Certain Categories of Diamonds” (the “ Diamonds Determination… Read more

1190. Do U.S. sanctions target persons for engaging in political speech, religious practice, or other constitutionally protected activities?

OFAC does not sanction persons for their engagement in activities subject to U.S. constitutional protection, such as protected speech or religious practice or for their religious beliefs; nor do U.S. persons violate OFAC sanctions for engaging in such constitutionally protected activity.… Read more

1191. On September 12, 2024, OFAC designated Ly Yong Phat (Ly), L.Y.P. Group Co., LTD (L.Y.P. Group), and the following entities owned by L.Y.P. Group under the Global Magnitsky sanctions authority: O-Smach Resort, Garden City Hotel, Koh Kong Resort, and Phnom Penh Hotel. Can I continue to engage in transactions or other dealings with other entities owned by Ly or L.Y.P. Group that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

Yes. Although transactions or other dealings involving Ly and L.Y.P. Group are prohibited as a result of OFAC's designation, OFAC concurrently issued Global Magnitsky General License (GL) 8 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ly or the L.Y.P.… Read more

1192. What is covered by the exclusions under 3(i) and 3(ii) related to the Export Administration Regulations (EAR) with respect to the IT and Software Services Determination?

The IT and Software Services Determination includes an exception for services related to software subject to the EAR, where: the export to Russia of such software is authorized or licensed by the Department of Commerce (Commerce); or where such software is not subject to the EAR and where the… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence