Frequently Asked Questions

593. If a blocked person holds an equity interest in a foreign entity, and the foreign entity is not itself a blocked person pursuant to OFAC’s fifty percent rule, can the foreign entity be sanctioned under section 10 of SSIDES, as amended by section 228 of CAATSA, and section 5 of UFSA, as amended by section 226 of CAATSA, for paying dividends to the blocked person?

593 … Whether paying dividends to a blocked person who holds an equity interest in the foreign company of less than fifty percent, individually or in the aggregate, would result in OFAC imposing sanctions under these authorities on the payer of the dividends depends on whether OFAC determines that… Read more

541. What activities can trigger sanctions on a foreign financial institution (FFI) under section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated into § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR)?

541 … Section 226 of CAATSA amended section 5 of UFSA to make the sanctions in that section, which were previously discretionary, mandatory. This section is implemented in § 589.209 of the URSR. Under § 589.209, FFIs face sanctions if the Secretary of the Treasury determines that they knowingly… Read more

542. How does OFAC interpret the following terms as used in section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated into § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR): “significant transaction,” “significant financial transaction,” and “facilitated?”

542 … “ Significant transaction ” and “ significant financial transaction ”– section 589.413 of the URSR states that for purposes of the UFSA prohibitions in § 589.209 , the Secretary of the Treasury will consider the totality of the facts and circumstances when determining whether transactions or… Read more

543. How will U.S. financial institutions and foreign financial institutions (FFIs) know that the Department of the Treasury has imposed prohibitions or strict conditions on FFIs’ correspondent accounts or payable-through accounts in the United States pursuant to section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated in § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR)?

543 … If, pursuant to § 589.209 of the URSR, Treasury decides to impose strict condition(s) on maintaining U.S. correspondent accounts or U.S. payable-through accounts for an FFI, or decides to prohibit the opening or maintaining of U.S. correspondent accounts or U.S. payable-through accounts for… Read more

544. What is the relationship between CAATSA and the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES)?

544 … Section 228 of CAATSA adds two sections to SSIDES that impose mandatory sanctions. … What is the relationship between CAATSA and the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 …

545. What do the following key terms in section 10 of the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES), as amended by section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), mean: “foreign person,” “knowingly,” “materially violate,” “facilitates . . . for or on behalf of,” “significant transaction,” and “deceptive or structured transaction”?

545 … “foreign person” – As stated in § 589.317 of the Ukraine-/Russia-Related Sanctions Regulations (URSR), the term foreign person for purposes of the SSIDES section 10 provisions in §§ 589.201(a)(6) and 589.413 means any citizen or national of a foreign state (including any such individual who… Read more

546. In section 10(a)(2)(A) of the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES), as amended by section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), and implemented in § 589.201(a)(6)(vii)(B)(1) of the Ukraine-/Russia-Related Sanctions Regulations (URSR), are persons “subject to sanctions imposed by the United States with respect to the Russian Federation” limited to persons listed on OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List, or does it also include persons identified on the Sectoral Sanctions Identifications (SSI) List, Non-SDN Menu-Based Sanctions (NS-MBS) List, or other OFAC sanctions lists?

546 … For purposes of section 10(a)(2)(A) of SSIDES and § 589.201(a)(6)(vii)(B)(1) of the URSR, OFAC will interpret the phrase “subject to sanctions imposed by the United States with respect to the Russian Federation” to be persons subject to sanctions under SSIDES, as amended, the Ukraine Freedom… Read more

552. Has the Treasury Department now sanctioned the individuals and entities included in its January 29, 2018 report on senior political figures, oligarchs, and parastatal entities of the Russian Federation?

552 … No. Pursuant to section 241 of Countering America’s Adversaries Through Sanctions Act of 2017 (Pub. L. 115-44), the Treasury Department, in consultation with Secretary of State and the Director of National Intelligence, delivered a report on January 29, 2018 to the specified congressional… Read more

627. What is the purpose of the Executive Order (E.O.) of September 20, 2018, “Authorizing the Implementation of Certain Sanctions Set Forth in the Countering America’s Adversaries Through Sanctions Act”?

627 … Title II of the Countering America’s Adversaries Through Sanctions Act, as amended ( CAATSA ), and the Ukraine Freedom Support Act of 2014, as amended ( UFSA ), provide for the imposition of certain sanctions with respect to the Russian Federation. The E.O. of September 20, 2018 provides… Read more

673. What is the purpose of Executive Order (E.O.) 13883, “Administration of Proliferation Sanctions and Amendment of Executive Order 12851”?

673 … E.O. 13883 delegates to the Secretary of the Treasury the implementation of the sanctions related to multilateral development bank assistance and to United States bank loans that are contained in the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991, as amended (“CBW… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence