Frequently Asked Questions

1038. For the purposes of the determination of May 8, 2022 made pursuant to Executive Order (E.O.) 14024, what is meant by the terms “accounting,” “trust and corporate formation services,” and “management consulting” sectors of the Russian Federation economy?

For the purposes of the determination of May 8, 2022 made pursuant to E.O. 14024 , OFAC interprets the following terms to include activities related to products and services in or involving the Russian Federation in the following: “Accounting sector” – includes the measurement, processing, and… Read more

1039. Are transactions ordinarily incident and necessary to the exportation or reexportation of agricultural commodities to, from, or transiting the Russian Federation that involve Agropromyshlennyi Kompleks Voronezhskii OOO, Anninskii Elevator OOO, and Azovskaya Zernovaya Kompaniya OOO authorized under OFAC sanctions?

Yes. On May 8, 2022, OFAC designated Agropromyshlennyi Kompleks Voronezhskii OOO, Anninskii Elevator OOO, and Azovskaya Zernovaya Kompaniya OOO pursuant to Executive Order (E.O.) 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or… Read more

1040. Are transactions related to telecommunications and certain internet-based communications that involve persons designated pursuant to Executive Order 14024 authorized by Russia-related General License (GL) 25G?

GL 25G authorizes certain transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR). In addition, GL 25G authorizes… 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?

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 Determination… Read more

1192. What is covered by the exclusions under 3(i) and 3(ii) related to the Export Administration Regulations (EAR) with respect to the IT and Software Services Determination?

The IT and Software Services Determination includes an exception for services related to software subject to the EAR, where: the export to Russia of such software is authorized or licensed by the Department of Commerce (Commerce); or where such software is not subject to the EAR and where the… Read more

1193. I am a U.S. company with a subsidiary organized and located in Russia. Can I provide the employees or contractors of my Russian subsidiary who are located in Russia with the services prohibited by the Information Technology (IT) and Software Services Determination under the exclusion "(1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a U.S. person?

Yes, as long as the services provided are within the employees’ or contractors’ scope of employment for or on behalf of the U.S. subsidiary company located in Russia. For additional information on the IT and Software Services Determination, see FAQs 1184 - 1188 , and FAQ 1192 …

1194. I am a U.S. company with a subsidiary located in a third country (other than Russia). My third-country subsidiary has an employee or contractor located in Russia. Can I provide that employee or contractor located in Russia with the services prohibited by the Information Technology (IT) and Software Services Determination under the exclusion "(1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a U.S. person"?

No. The scope of the exclusion applies only to U.S.-owned or controlled entities located in Russia and their employees and contractors acting within the scope of their employment. See FAQ 1193 . A U.S. person may not provide a service prohibited by the IT and Software Services Determination to a… Read more

1195. A U.S. company located in the United States has an employee or contractor located in Russia working directly for the U.S. company. Can the U.S. company provide that employee or contractor located in Russia with the services prohibited by the Information Technology (IT) and Software Services Determination under the exclusion "(1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a U.S. person"?

No. The scope of the exclusion applies only to U.S.-owned or controlled entities located in Russia, and their employees and contractors acting within the scope of their employment. See FAQ 1193 . A U.S. person may not provide a service prohibited by the IT and Software Services Determination to a… Read more

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?

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 economy… Read more

969. Does OFAC’s 50 Percent Rule apply to foreign financial institutions listed in Annex 1 to Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?

Yes. The prohibitions of the Russia-related CAPTA Directive apply to any foreign financial institution listed in Annex 1 to the Russia-related CAPTA Directive or otherwise determined to be subject to the prohibitions of the Russia-related CAPTA Directive, “or their property or interests in… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence