Frequently Asked Questions

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

1188. Does the determination, “Prohibition on Certain Information Technology and Software Services,” pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”) prohibit U.S. persons from providing services to persons located outside of the Russian Federation that are owned or controlled by persons located in the Russian Federation?

1188 … No, provided that the provision of services is not an indirect export to a person located in the Russian Federation. For the purposes of the IT and Software Services Determination , OFAC interprets the “indirect” provision of the prohibited services to include when the benefit of the… Read more

1083. What actions were taken on September 15, 2022 related to certain quantum computing services?

1083 … On September 15, 2022, the Director of OFAC, in consultation with the Department of State, issued a determination pursuant to Executive Order (E.O.) 14071 , “Prohibitions Related to Certain Quantum Computing Services,” prohibiting the exportation, reexportation, sale, or supply, directly or… Read more

1084. For the purposes of the determination of September 15, 2022 made pursuant to Executive Order (E.O.) 14071, “Prohibitions Related to Certain Quantum Computing Services” (“the determination”), what is meant by the term “quantum computing services”?

1084 … For the purposes of the determination , OFAC anticipates publishing regulations defining this term to include any of the following services when related to quantum computing, quantum computers, electronic assemblies thereof, or cryogenic refrigeration systems related to quantum computing: … Read more

1086. For the purposes of the determination of September 15, 2022 made pursuant to Executive Order (E.O.) 14024, what is meant by the term “quantum computing sector of the Russian Federation economy”?

1086 … For the purposes of the determination of September 15, 2022 made pursuant to E.O. 14024 , OFAC interprets the term “quantum computing sector of the Russian Federation economy” to include activities related to products and services in or involving the Russian Federation in research,… Read more

1091. Do non-U.S. persons face sanctions risk for supporting Russia following its sham referenda, purported annexation, and continued occupation of the Kherson, Zaporizhzhya, Donetsk, and Luhansk regions of Ukraine?

1091 … Yes. On September 23, G7 Leaders issued a statement condemning Russia’s sham referenda and noting their collective readiness to impose further economic costs on Russia, and on individuals and entities both inside and outside of Russia that provide political or economic support for Russia’s… Read more

1092. Do non-U.S. companies risk exposure to sanctions for providing ammunition or other military goods to Russia or for supporting Russia’s military-industrial complex?

1092 … Yes. Multiple Russia-related sanctions authorities authorize sanctions against non-U.S. persons that provide goods, services, or other support for Russia’s military-industrial complex. For example, OFAC may block any person determined to operate or have operated in the defense and related… Read more

1094. Is crude oil of Russian Federation origin that is loaded onto a vessel at the port of loading for maritime transport prior to December 5, 2022 subject to the price cap?

1094 … No, provided the oil is unloaded at the port of destination prior to 12:01 a.m., eastern standard time, January 19, 2023. Crude oil of Russian Federation origin that is loaded onto a vessel at the port of loading prior to 12:01 a.m., eastern standard time, December 5, 2022, and unloaded at… Read more

1096. Do U.S. sanctions prohibit U.S. persons from engaging in transactions that are ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation located in or outside the United States?

1096 … OFAC issued Russia-related General License (GL) 53A to authorize U.S. persons to engage in all transactions ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation ("Russian missions"), where the transactions… Read more

987. If a U.S. person entered into a revolving credit facility or long-term loan agreement for an entity determined to be subject to Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prior to the relevant sanctions effective date described in the Russia-related Entities Directive, what are the restrictions on drawdowns from that facility? Do all drawdowns and disbursements pursuant to the parent agreement need to carry repayment terms of 14 days or less?

987 … If a U.S. person entered into a long-term credit facility or loan agreement prior to the relevant sanctions effective date described in the Russia-related Entities Directive, drawdowns and disbursements with repayment terms of 14 days or less are permitted. In addition, drawdowns and… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence