Frequently Asked Questions

1182. Are foreign financial institutions (FFIs) subject to sanctions risk for providing all financial services involving persons blocked pursuant to Executive Order (E.O.) 14024, as amended? What about agricultural, medical, and other transactions authorized by OFAC General Licenses?

Treasury remains focused on counteracting activity that involves sanctions evasion or third-country support to Russia's military-industrial base. At the same time, legitimate humanitarian activity and agricultural and medical trade are not the target of our sanctions. Accordingly, FFIs may continue… Read more

1117. My company provides goods or services to, or engages in trade with, persons that operate or have operated in the metals and mining sector of the Russian Federation economy. Does my company risk being sanctioned by OFAC?

The determination made on February 24, 2023 pursuant to Executive Order (E.O.) 14024 authorizes sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy. Non-U.S. persons may also be exposed to sanctions for activities with… 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)?

OFAC issued Russia-related General License (GL) 132 to authorize transactions involving the Paks II civil nuclear power plant project in Hungary, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive.… Read more

978. For transactions authorized under Russia-related General Licenses (GL) 6D, 7A, 115C, or 132, what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024?

GLs 6D , 7A , or 115C , or 132 do not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of entities subject to the prohibitions of Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through… Read more

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

GL 115C 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 and… 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) 13P authorize transactions that involve the payment of this exit tax?

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… 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) 115C under Executive Order (E.O.) 14024. What can I do?

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 115C can contact the OFAC Compliance Hotline . Updated:… Read more

1224. What negotiations does Russia-related General License 131C authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?

On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia's energy sector and degrade Russia's ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-… Read more

1225. What activities do Russia-related General License 128B and General License 131C authorize related to Lukoil International GmbH (LIG)?

OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries ("LIG Entities"): GL 128B and GL 131C . The GLs are similar but have different expiration dates and terms as each serves a different purpose. To mitigate the… Read more

Frequently Asked Questions

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