Frequently Asked Questions

412. What do the prohibitions contained in Directive 4 mean? What is the scope of prohibited services?

Directive 4, as amended on October 31, 2017 in accordance with CAATSA , imposes two prohibitions on the provision, exportation, or reexportation of goods, services (except for financial services), or technology for certain activities involving persons subject to Directive 4, their property, or… Read more

413. For the purposes of Directive 4, how does OFAC define "deepwater" projects that have the potential to produce oil?

A project is considered to be a deepwater project if the project involves underwater activities at depths of more than 500 feet. …

414. Does Directive 4 apply to projects that have the potential to produce gas?

If a deepwater, Arctic offshore, or shale project has the potential to produce oil, and the other requirements for either of the Directive 4 prohibitions are fully satisfied, then the relevant Directive 4 prohibition applies, irrespective of whether the project also has the potential to produce gas… Read more

415. For persons determined to be subject to multiple Directives, how do the prohibitions and exemptions listed under one Directive affect prohibitions and exemptions under the other Directives?

Each Directive operates independently of the others. If a transaction involves a person subject to two Directives, for example, a U.S. person engaging in that transaction must comply with the requirements of both Directives. Exemptions in one Directive apply only to the prohibitions contained in… Read more

416. What does the "sanctions effective date" mean in the context of sectoral sanctions pursuant to E.O. 13662?

For purposes of the sectoral sanctions, "sanctions effective date" means the date a person is determined to be subject to the prohibition(s) of the relevant Directive . When a person has been previously determined to be subject to a Directive and the prohibitions in the Directive are subsequently… Read more

418. How does OFAC interpret the term "shale projects" with respect to the prohibitions in Directive 4, now incorporated into § 589.205 of the Ukraine-/Russia-Related Sanctions Regulations (URSR)?

The term "shale projects," as defined in § 589.334 of the URSR, includes projects that have the potential to produce oil from resources located in shale formations as well as projects that have the potential to produce oil from resources located in fine-grained sedimentary rock formations including… Read more

419. How should U.S. persons account for the debt prohibitions under Directives 1, 2, and 3 as they relate to payment terms for the following types of transactions: (1) the sale of goods to an SSI entity, (2) the provision of services to and subscription arrangements involving SSI entities, and (3) progress payments for long-term projects?

U.S. persons may engage in commercial transactions with SSI entities provided that any such transactions do not represent a direct or indirect dealing in prohibited debt or equity. Because offering payment terms of longer than the applicable tenor specified in the relevant Directive to an SSI… Read more

420. Under Directive 4, does the term "production" encompass activities such as transportation, refining, or other dealings in oil extracted from deepwater, Arctic offshore, or shale projects?

For the purposes of Directive 4 , the term "production" refers to the lifting of oil to the surface and the gathering, treating, field processing, and field storage of such oil. The production stage of a project ends when extracted oil is transported out of a field production storage tank or… Read more

919. How do sanctions related to U.S. bank loans imposed on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Act of 1991 (CBW Act), as announced by the State Department on August 20, 2021, affect existing prohibitions?

The prohibitions announced by the State Department on August 20, 2021 related to U.S. bank loans have the same scope as those imposed by OFAC in August 2019 under the CBW Act Directive . Please see FAQs 675 – 678 for additional information. Independent of the CBW Act Directive, OFAC has imposed… Read more

920. How are the sanctions related to import restrictions imposed on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Act of 1991 (CBW Act), as announced by the State Department on August 20, 2021, being implemented?

The announced import restrictions related to the permanent importation of firearms and ammunition that are the growth, product, or manufacture of the Russian Federation will be implemented by the U.S. Department of Justice, Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). OFAC has… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence