Frequently Asked Questions

1214. Does the determination of January 10, 2025, made pursuant to Executive Order (E.O.) 14024 (the "January 2025 Energy Sector Determination") mean that all persons that operate or have operated in this sector of the Russian Federation economy are sanctioned by OFAC?

1214 … No. On January 10, 2025, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the energy sector of the Russian… Read more

1215. Why did OFAC issue General License (GL) 26 ("Transactions Authorized Pursuant to the Russian Harmful Foreign Activities Sanctions Regulations") in the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589 (URSR)?

1215 … GL 26 applies to transactions involving specified persons identified in the Annex to GL 26, who are designated under both the URSR and the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR). The purpose of GL 26 is to ensure that transactions authorized or… Read more

1216. What action did Treasury take on January 10, 2025 with regard to the provision of petroleum services to Russia?

1216 … In line with G7 efforts to reduce Russian revenues from energy, on January 10, 2025, Treasury issued a determination pursuant to Executive Order (E.O.) 14071 prohibiting petroleum services to Russia. See The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition… Read more

1217. I am a U.S. service provider. Following the January 10, 2025 determinations under Executive Order (E.O.) 14024 and E.O. 14071 (the Energy Sector Determination and Petroleum Services Determination, respectively), am I still authorized to provide certain services relating to the maritime transport of Russian crude oil and Russian petroleum products to a non-sanctioned person operating in the energy sector of the Russian economy, so long as the crude oil or petroleum products are purchased at or below the price cap?

1217 … Yes, as long as the provision of services does not involve an entity blocked pursuant to E.O. 14024 and is not otherwise prohibited by OFAC sanctions. The price cap policy does not authorize transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31… 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

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

1118. As of December 2022, the Government of the Russian Federation may require a so-called "exit tax" payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called "exit tax"? Does Russia-related General License (GL) 13M authorize transactions that involve the payment of this exit tax?

1118 … The 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… Read more

999. What authorizations exist for entities subject to 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)?

999 … OFAC issued Russia-related General Licenses (GLs) 8L and 115A to authorize the wind-down of certain energy-related transactions and civil nuclear energy-related transactions, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related… Read more

Frequently Asked Questions

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