Frequently Asked Questions

1021. Do the prohibitions of Executive Order (E.O.) 14024 and other Russia-related sanctions extend to virtual currency?

Yes. The Office of Foreign Assets Control (OFAC) has imposed expansive sanctions actions against certain Russian entities and individuals pursuant to E.O. 14024 , in addition to other authorities. All U.S. persons are required to comply with OFAC regulations, regardless of whether a transaction… Read more

1026. Are non-U.S. persons exposed to sanctions if they continue to import to non-U.S. jurisdictions certain products of Russian Federation origin that are banned from the United States pursuant to Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression”?

E.O. of March 11, 2022 prohibits the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; and non-industrial diamonds of Russian Federation origin. To the extent the import of such products of Russian Federation origin to jurisdictions outside of the… Read more

1025. Executive Order (E.O.) 14068, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression” prohibits the importation into the United States of fish, seafood, and preparations thereof of Russian Federation origin. How does this affect Russia-related General License (GL) 6C?

Russia-related GL 6C (“Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials”) remains valid and authorizes, among other things, certain transactions… Read more

1024. I have a shipment of a certain product(s) listed in Executive Order (E.O.) 14068 en route to the United States that were contracted prior to March 11, 2022. Can I find a new buyer for this shipment, re-direct the shipment to a country other than the United States, or import the product(s) and comply with the import ban?

Yes. E.O. 14068 prohibits the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; and non-industrial diamonds of Russian Federation origin. It does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments outside the… Read more

1022. What does Executive Order (E.O.) 14068, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” do?

E.O. 14068 prohibits the following activities: the importation into the United States of the following products of Russian Federation origin: fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds; and any other products of Russian Federation origin as may be… Read more

1027. For the purposes of Executive Order (E.O.) 14068, as amended, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” and associated determinations, what is meant by the terms “Russian Federation origin,” “fish, seafood, and preparations thereof,” “alcoholic beverages,” “unsorted diamonds,” and “non-industrial diamonds”?

For the purposes of E.O. 14068 , as amended by E.O. 14114, the Office of Foreign Assets Control anticipates publishing regulations defining these terms to include the following: “Russian Federation origin” – see FAQ 1019 . “fish, seafood, and preparations thereof” – articles defined at Harmonized… Read more

1028. Does the U.S. dollar-denominated banknote export ban imposed by Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” prohibit sending noncommercial, personal remittances denominated in U.S. dollars to the Russia Federation (or to individuals ordinarily resident in the Russia Federation)?

E.O. of March 11, 2022 prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian… Read more

1029. How do the prohibitions of Executive Order (E.O.) 14024 and other Russia-related sanctions impact gold-related transactions or persons participating in the gold market?

Gold-related transactions involving the Russian Federation may be sanctionable under E.O. 14024 or other Russia-related sanctions authorities. For example, E.O. 14024 authorizes sanctions against: Persons determined to be responsible for or complicit in, or to have directly or indirectly engaged… Read more

1030. What obligations do operators of credit card systems have under the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. part 587 (RuHSR), and the Belarus Sanctions Regulations, 31 C.F.R. part 548 (BSR), with regard to payment cards issued by sanctioned Russian financial institutions?

Pursuant to the RuHSR and BSR, U.S. persons, including U.S. operators of credit card systems and U.S. acquirers, are prohibited from processing transactions involving certain sanctioned foreign financial institutions, unless exempt or authorized by OFAC. Non-U.S. operators of credit card systems… Read more

1033. What actions were taken on May 8, 2022 related to certain accounting, trust and corporate formation, and management consulting services?

On May 8, 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 Accounting, Trust and Corporate Formation, and Management Consulting Services," prohibiting the exportation,… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence