Frequently Asked Questions

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

444. How will Treasury decide whom to sanction under this authority?

444 … Executive Order (E.O.) 13694, as amended on December 29, 2016, focuses on specific harms caused by significant malicious cyber-enabled activities, and directs the Secretary of the Treasury, in consultation with the Attorney General and the Secretary of State, to impose sanctions on those… Read more

445. What are my compliance obligations with respect to E.O. 13694, as amended?

445 … As with many of the sanctions programs that Treasury administers, U.S. persons (and persons otherwise subject to OFAC jurisdiction) must ensure that they are not engaging in trade or other transactions with persons named on OFAC’s SDN List pursuant to E.O. 13694, as amended, or any entity… Read more

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

452. Are these sanctions consistent with international obligations?

452 … As with all financial sanctions programs Treasury administers, these measures will be implemented in accordance with domestic law and our international obligations. … Are these sanctions consistent with international …

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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence