Frequently Asked Questions

970. Are foreign financial institutions (FFIs) located outside of Russia potentially subject to the prohibitions of 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)?

970 … Yes. The prohibitions of the Russia-related CAPTA Directive apply to a U.S. financial institution’s opening or maintaining of a correspondent account or payable-through account for or on behalf of, or processing of a transaction involving, any FFI, wherever located outside of the United… Read more

971. Are the prohibitions of 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) limited to transactions denominated in U.S. dollars?

971 … No. The prohibitions of the Russia-related CAPTA Directive apply with respect to any currency. For example, a foreign branch of a U.S. financial institution may not open or maintain a correspondent account for or on behalf of, or process a transaction involving, a foreign financial… Read more

973. I am a U.S. individual or company that maintains an account at a foreign financial institution sanctioned pursuant to Directive 2 under Executive Order (E.O.) 14024. What are my obligations?

973 … With respect to foreign financial institutions subject to the prohibitions of Directive 2 under E.O. 14024 , “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” ( Russia-related CAPTA Directive ),… Read more

974. What Russian financial institutions were blocked in February 2022 pursuant to Executive Order (E.O.) 14024, and what activities are prohibited as a result?

974 … On February 22, 2022, the Office of Foreign Assets Control (OFAC) designated specified Russian financial institutions pursuant to E.O. 14024 , including the State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), Promsvyazbank Public Joint Stock Company, and… Read more

975. Is there a wind-down period for transactions involving the Russian financial institutions blocked in February 2022 pursuant to Executive Order (E.O.) 14024? What transactions are authorized during the wind-down period?

975 … For certain Russian financial institutions blocked in February 2022 pursuant to E.O. 14024 , a short-term wind-down period is authorized. General License (GL) 3 authorizes a wind-down period of 30 days for transactions involving State Corporation Bank for Development and Foreign Economic… Read more

976. Can a U.S. financial institution process wind down transactions related to energy where a Russian financial institution sanctioned pursuant to Executive Order (E.O.) 14024 is involved?

976 … On January 10, 2025, OFAC issued amended General License (GL) 8L to authorize the wind-down of transactions related to energy involving certain Russian financial institutions sanctioned pursuant to E.O. 14024 through 12:01 a.m. eastern daylight time, March 12, 2025. GL 8L authorizes certain… Read more

977. What are transactions "related to energy" for purposes of Russia-related General License (GL) 8L?

977 … On January 10, 2025, OFAC issued amended GL 8L to authorize the wind-down of transactions related to energy involving certain Russian financial institutions sanctioned pursuant to E.O. 14024 through 12:01 a.m. eastern daylight time, March 12, 2025. For the purposes of GL 8L , the term "… Read more

978. For transactions authorized under Russia-related General Licenses (GL) 6D, 7A, 8L, or GL 115A what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024?

978 … On January 10, 2025, OFAC issued amended General License (GL) 8L to authorize the wind-down of transactions related to energy involving certain Russian financial institutions sanctioned pursuant to E.O. 14024 through 12:01 a.m. eastern daylight time, March 12, 2025. GLs 6D , 7A , 8L , or 115A… Read more

979. I am a U.S. person. Can I rely on a person sanctioned pursuant to Executive Order (E.O.) 14024 in connection with transactions for official business of an international organization, certain humanitarian-related trade, or the response to the Coronavirus Disease 2019 (COVID-19) pandemic?

979 … Yes, U.S. persons supporting activities undertaken for the official business of certain international organizations or entities, certain humanitarian-related trade, or the response to the COVID-19 pandemic may continue to engage in such activity involving persons sanctioned pursuant to E.O.… Read more

980. Do non-U.S. persons risk being sanctioned for engaging in activity with persons sanctioned pursuant to Executive Order (E.O.) 14024?

980 … OFAC evaluates a range of factors when developing sanctions targets, consistent with foreign policy and national security goals. In the context of blocking sanctions, non-U.S. persons may be exposed to sanctions risk in relation to activities with persons subject to blocking sanctions… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence