Frequently Asked Questions

1129. Do blocking sanctions issued by the State Department on May 19, 2023 on Polimetall AO apply to its corporate parent and affiliates?

1129 … On May 19, 2023, the Department of State designated Russia-based Polimetall AO pursuant to Executive Order (E.O.) 14024 . These blocking sanctions apply only to this entity and any entities in which it owns, directly or indirectly, a 50 percent or greater interest. Neither the Department… Read more

1131. Is LETTERONE HOLDINGS S.A. (LetterOne) blocked as a result of the designation of Petr Olegovich Aven, Mikhail Maratovich Fridman, German Borisovich Khan, and Alexey Viktorovich Kuzmichev?

1131 … No. OFAC has not designated LetterOne and, based on information available to OFAC, LetterOne is not owned 50 percent or more by blocked persons or otherwise considered the blocked property or interest in property of blocked persons, including Petr Olegovich Aven, Mikhail Maratovich Fridman… Read more

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

1203 … GL 115B 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

1215. Why did OFAC issue General License (GL) 26 ("Transactions Authorized Pursuant to the Russian Harmful Foreign Activities Sanctions Regulations") in the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589 (URSR)?

1215 … GL 26 applies to transactions involving specified persons identified in the Annex to GL 26, who are designated under both the URSR and the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR). The purpose of GL 26 is to ensure that transactions authorized or… Read more

1217. I am a U.S. service provider. Following the January 10, 2025 determinations under Executive Order (E.O.) 14024 and E.O. 14071 (the Energy Sector Determination and Petroleum Services Determination, respectively), am I still authorized to provide certain services relating to the maritime transport of Russian crude oil and Russian petroleum products to a non-sanctioned person operating in the energy sector of the Russian economy, so long as the crude oil or petroleum products are purchased at or below the price cap?

1217 … Yes, as long as the provision of services does not involve an entity blocked pursuant to E.O. 14024 and is not otherwise prohibited by OFAC sanctions. The price cap policy does not authorize transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31… 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)?

999 … OFAC issued Russia-related General License (GL) 115B to authorize civil nuclear energy-related transactions, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive . OFAC issued GL 13O to authorize… 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) 13O authorize transactions that involve the payment of this exit tax?

1118 … 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… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence