Frequently Asked Questions

On February 24, 2023, the Director of OFAC, in consultation with the Department of State, issued a sectoral determination pursuant to Executive Order (E.O.) 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the metals and mining… Read more

For the purposes of the determination of February 24, 2023 made pursuant to E.O. 14024 , OFAC anticipates publishing regulations defining the term “metals and mining sector of the Russian Federation economy” to include any act, process, or industry of extracting, at the surface or underground, ores… Read more

No. The Director of OFAC, in consultation with the State Department, has 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 metals and mining sector of the Russian Federation economy. A… Read more

In line with G7 commitments and in response to the Government of the Russian Federation’s continued efforts to reorient its economy and government resources to support its war effort, Treasury has updated its definition of Russia’s military-industrial base to include all persons blocked pursuant to… Read more

In line with G7 efforts to disrupt Russia’s defense industry’s reliance on western IT systems, on June 12, 2024, Treasury issued a determination that restricts the provision of certain IT and software-related services to Russia.  The determination, “ Prohibition on Certain Information Technology… Read more

IT consultancy and design services include the development and implementation of software, as well as assistance or advice relating to the development and implementation of software, including the supply and installation of bespoke software.  However, the retail sale of off-the-shelf software,… Read more

The IT and Software Services Determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of both IT support services and cloud-based services for the Covered Software to a person located in… Read more

OFAC expects to promulgate regulations that define or interpret these terms as follows: The term enterprise management software means the following types of software:  enterprise resource planning (ERP), customer relationship management (CRM), business intelligence (BI), supply chain management (… Read more

No, provided that the provision of services is not an indirect export to a person located in the Russian Federation.  For the purposes of the IT and Software Services Determination , OFAC interprets the “indirect” provision of the prohibited services to include when the benefit of the services is… Read more

No, provided the oil is unloaded at the port of destination prior to 12:01 a.m., eastern standard time, January 19, 2023.  Crude oil of Russian Federation origin that is loaded onto a vessel at the port of loading prior to 12:01 a.m., eastern standard time, December 5, 2022, and unloaded at the… Read more