Frequently Asked Questions

922. What does Executive Order (E.O.) of September 17, 2021, “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” do?

922 … 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… Read more

923. Do blocking sanctions imposed on persons pursuant to Executive Order (E.O.) of September 17, 2021, “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” automatically apply to entities owned in whole or in part by sanctioned persons?

923 … 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… Read more

924. Do non-blocking sanctions imposed on persons pursuant to Executive Order (E.O.) of September 17, 2021, “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” automatically apply to entities owned in whole or in part by sanctioned persons?

924 … 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,… Read more

926. What activities are authorized pursuant to Ethiopia General License (GL) 2, “Certain Transactions in Support of Nongovernmental Organizations’ Activities”?

926 … 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… Read more

927. Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions and activities that would be authorized for U.S. persons pursuant to Executive Order (E.O.) of September 17, 2021, “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia”?

927 … 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… Read more

935. Does the blocking of Hidri Trust and Red Sea Trading Corporation (RSTC) restrict the ability of U.S. and non-U.S. persons to engage in humanitarian-related transactions or activity in Eritrea or Ethiopia?

935 … 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… Read more

936. Does OFAC’s 50 Percent Rule apply to Hidri Trust and Red Sea Trading Corporation (RSTC)?

936 … 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… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence