Frequently Asked Questions

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

1203. What does General License (GL) 115A ("Authorizing Certain Transactions Related to Civil Nuclear Energy") authorize with respect to civil nuclear energy-related payments?

1203 … GL 115A generally authorizes certain transactions related to civil nuclear energy involving certain entities that are sanctioned pursuant to Executive Order 14024. Civil nuclear energy means the following activities when undertaken solely to maintain or support civil nuclear energy projects… Read more

1204. On December 27, 2024, OFAC designated Bidzina Ivanishvili (Ivanishvili) pursuant to Executive Order (E.O.) 14024. Can I continue to engage in transactions or other dealings with entities owned by Ivanishvili that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

1204 … Yes. Although transactions or other dealings involving Ivanishvili are generally prohibited as a result of OFAC's designation, OFAC concurrently issued General License (GL) 116 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ivanishvili provided… Read more

1213. For the purposes of the determination of January 10, 2025 made pursuant to Executive Order (E.O.) 14024 (the "January 2025 Energy Sector Determination"), what is meant by the term "energy sector of the Russian Federation economy"?

1213 … 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

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

1010. My company transports Russian oil for sale to the United States and third countries. Can I continue to transport or sell Russian-origin oil without violating sanctions pursuant to Executive Order (E.O.) 14024?

1010 … The energy sector of the Russian Federation economy itself is not subject to comprehensive sanctions. However, prohibitions or restrictions may apply to certain energy-related transactions under several sanctions authorities, including prohibitions issued pursuant to E.O. 13662 , E.O. 14024… Read more

1011. My U.S. bank refused to process a requested payment related to energy despite the authorization in Russia-related General License (GL) 115A under Executive Order (E.O.) 14024. What can I do?

1011 … The Office of Foreign Assets Control (OFAC) encourages persons to connect with their financial institution regarding the status of any payment. In addition, persons with questions about engaging in or processing transactions related to GL 115A can contact the OFAC Compliance Hotline .… Read more

1012. Do I have to wind down energy-related transactions by the expiration date of Russia-related General License (GL) 8L?

1012 … On January 10, 2025, the Office of Foreign Assets Control (OFAC) amended GL 8L to authorize the wind-down of energy-related transactions through 12:01 a.m. eastern daylight time, March 12, 2025. OFAC issued GL 115A to authorize transactions related to civil nuclear energy involving certain… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence