Frequently Asked Questions

501. What does General License 1C (GL 1C), “Authorizing Certain Transactions with the Federal Security Service,” authorize?

501 … 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,… Read more

502. What sanctions remain in place on the Federal Security Service following the issuance of GL 1C?

502 … 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… Read more

503. Does GL 1C authorize the exportation of hardware or software directly to the Federal Security Service, or where the Federal Security Service is the end user of such hardware and software?

503 … 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… Read more

504. I understand that travel to Russia involves clearing Russian border control, which is part of the FSB. Do I need a license from OFAC to travel to Russia, or to clear Russian customs?

504 … No, the sanctions on the FSB do not apply to transactions by U.S. persons that are ordinarily incident to travel to or from Russia, including those transactions required to enter into or exit the country (i.e., complying with Russian border control requirements). … I understand that travel to… Read more

447. What will significant malicious “cyber-enabled” activities mean for the purposes of Executive Order (E.O.) 13694?

447 … We anticipate that regulations to be promulgated will define “cyber-enabled” activities to include any act that is primarily accomplished through or facilitated by computers or other electronic devices. For purposes of E.O. 13694 , malicious cyber-enabled activities include deliberate… Read more

448. I conduct cyber-related activities for legitimate educational, network defense, or research purposes only. Am I vulnerable to the application of sanctions under this authority for these activities?

448 … The measures in this order are directed against significant malicious cyber-enabled activities that have the purpose or effect of causing specific enumerated harms, and are not designed to prevent or interfere with legitimate cyber-enabled academic, business, or non-profit activities. The U.S… Read more

449. I administer a network for my employer and I regularly deny access to certain services and systems (e.g., retail websites, social media platforms) in order to ensure the performance of the network for authorized business activities. Could I or my employer be sanctioned for this?

449 … The measures in this order are designed to address the threat posed by individuals and entities engaged in significant malicious cyber-enabled activities that have the purpose or effect of causing specific enumerated harms. These measures are not designed to prevent or interfere with… Read more

450. Will Treasury impose sanctions on persons whose personal computers (or other networked electronic devices) are, without their knowledge or consent, used in malicious cyber-enabled activities (e.g., in denial-of-service attacks against U.S. financial institutions)?

450 … No. These sanctions are designed to target those actors whose malicious cyber-enabled conduct is reasonably likely to result in, or have materially contributed to, a significant threat to the national security, foreign policy, or economic health or financial stability of the United States.… Read more

451. How do financial sanctions relate to existing legal authorities in this context?

451 … The United States’ whole-of-government strategy to combat cyber threats draws from a broad range of tools and authorities to respond to the growing and evolving threat posed by malicious cyber actors. Similar to our approach to global threats from terrorists, narcotics traffickers, and… Read more

489. The President has amended E.O. 13694 to cover “misappropriation of information.” What does that term mean? Does that mean that Treasury will impose sanctions related to the publication of information by American whistleblowers or members of the press?

489 … No. This authority does not target American whistleblower activity or constitutionally protected activity. The E.O. defines misappropriation to be the “taking or obtaining by improper means, without permission or consent, or under false pretenses.” Importantly, to be eligible for sanctions… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence