Frequently Asked Questions

1131. Is LETTERONE HOLDINGS S.A. (LetterOne) blocked as a result of the designation of Petr Olegovich Aven, Mikhail Maratovich Fridman, German Borisovich Khan, and Alexey Viktorovich Kuzmichev?

1131 … No. OFAC has not designated LetterOne and, based on information available to OFAC, LetterOne is not owned 50 percent or more by blocked persons or otherwise considered the blocked property or interest in property of blocked persons, including Petr Olegovich Aven, Mikhail Maratovich Fridman… 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?

1189 … 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… 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?

1192 … 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… Read more

1193. I am a U.S. company with a subsidiary organized and located in Russia. Can I provide the employees or contractors of my Russian subsidiary who are located in Russia with the services prohibited by the Information Technology (IT) and Software Services Determination under the exclusion "(1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a U.S. person?

1193 … Yes, as long as the services provided are within the employees’ or contractors’ scope of employment for or on behalf of the U.S. subsidiary company located in Russia. For additional information on the IT and Software Services Determination, see FAQs 1184 - 1188 , and FAQ 1192 . … I am a U.S… Read more

1194. I am a U.S. company with a subsidiary located in a third country (other than Russia). My third-country subsidiary has an employee or contractor located in Russia. Can I provide that employee or contractor located in Russia with the services prohibited by the Information Technology (IT) and Software Services Determination under the exclusion "(1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a U.S. person"?

1194 … No. The scope of the exclusion applies only to U.S.-owned or controlled entities located in Russia and their employees and contractors acting within the scope of their employment. See FAQ 1193 . A U.S. person may not provide a service prohibited by the IT and Software Services Determination… Read more

1195. A U.S. company located in the United States has an employee or contractor located in Russia working directly for the U.S. company. Can the U.S. company provide that employee or contractor located in Russia with the services prohibited by the Information Technology (IT) and Software Services Determination under the exclusion "(1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a U.S. person"?

1195 … No. The scope of the exclusion applies only to U.S.-owned or controlled entities located in Russia, and their employees and contractors acting within the scope of their employment. See FAQ 1193 . A U.S. person may not provide a service prohibited by the IT and Software Services Determination… Read more

1197. I'm a U.S. person with securities held at the National Settlement Depository (NSD), which were transferred pursuant to Russian Decree 840 to another Russian registrar. Am I required to block these securities?

1197 … Yes. On June 12, 2024, OFAC designated the National Settlement Depository (NSD), along with the Moscow Exchange (MOEX) and the National Clearing Center (NCC) pursuant to Executive Order (E.O.) 14024 for operating or having operated in the financial services sector of the Russian Federation… Read more

1198. In light of the designation of Shreya Life Sciences Private Limited (Shreya), are U.S. persons authorized to engage in transactions related to pharmaceutical and other humanitarian-related goods involving Shreya and its subsidiaries?

1198 … Yes. As a general matter, humanitarian trade is not the target of U.S. sanctions. OFAC has issued Russia-related General License (GL) 6D , which authorizes, among other things, certain transactions related to the production, manufacturing, sale, transport, or provision of medicine and… Read more

1201. What authorizations exist for diplomatic or consular missions operating in or outside of Russia and Russian diplomatic or consular missions operating abroad?

1201 … The Office of Foreign Assets Control (OFAC) has issued several authorizations related to U.S. and third-country diplomatic or consular missions operating in or outside of Russia and Russian diplomatic or consular missions operating abroad. Russian Diplomatic or Consular Missions, Wherever… Read more

1202. Following the November 21, 2024 designation of Russian financial institutions, Treasury has now designated a significant number of financial institutions in Russia. Will this negatively impact the processing of personal, non-commercial remittances to or from Russia?

1202 … No. Treasury's sanctions target Russian financial institutions that have continued to help Russia gain access to the critical goods it needs to prosecute its war in Ukraine. As a general matter, personal, non-commercial remittances are not the target of sanctions imposed by the United States… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence