Frequently Asked Questions

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?

919 … 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… 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?

920 … 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

869. If a person is subject to non-blocking menu-based sanctions described in section 235(a) of the Countering America’s Adversaries Through Sanctions Act (CAATSA), do the same non-blocking sanctions apply to entities owned 50 percent or more by the listed person?

869 … No. If a person is listed on OFAC’s Non-SDN Menu-Based Sanctions List (NS-MBS List) as subject to only a combination of the sanctions described in section 235(a)(1-8) and (10-11) of CAATSA , as implemented by Executive Order (E.O.) 13849 , these non-blocking sanctions do not apply to an… Read more

870. On December 14, 2020, OFAC added a person to the Non-SDN Menu-Based Sanctions List (NS-MBS List) and indicated that the person was subject to the loan and credit-related sanction described in section 235(a)(3) of the Countering America’s Adversaries Through Sanctions Act (CAATSA). What does this sanction prohibit?

870 … With respect to a person on the NS-MBS List subject to section 235(a)(3) of CAATSA , as implemented by section 1(a)(i) of Executive Order (E.O.) 13849 , U.S. financial institutions are prohibited from making loans or providing credits to the identified person totaling more than $10,000,000 in… Read more

371. What does OFAC interpret to be debt and equity? Are there other prohibited activities under Directives 1, 2, and 3 under Executive Order (E.O.) 13662? Can U.S. financial institutions continue to maintain correspondent accounts and process U.S. dollar-clearing transactions for the entities subject to the prohibitions of these directives?

371 … The term debt includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper. The term equity includes stocks, share issuances, depositary receipts, or any other evidence of title or ownership. The… Read more

1006. What does Executive Order (E.O.) 14065 do?

1006 … E.O. 14065 prohibits the following activities with the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine and such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the… Read more

1007. Are U.S. persons authorized to engage in certain activity with the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions")?

1007 … U.S. persons are authorized through a variety of Ukraine-related general licenses (GLs) to support certain humanitarian efforts and other activity in the Covered Regions, including transactions related to the export of food or medicine, the response to the Coronavirus Disease 2019 (COVID-19… Read more

1008. Is there a wind-down period for the prohibitions imposed in Executive Order (E.O.) 14065?

1008 … Yes. Through 12:01 a.m. eastern daylight time on March 23, 2022, Ukraine-related General License 17 authorizes transactions that are ordinarily incident and necessary to the wind down of transactions involving the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR… Read more

1009. Does Executive Order (E.O.) 14065 block the entire Donetsk and Luhansk oblasts?

1009 … No. E.O. 14065 targets the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”). In… Read more

372. Do Directives 1, 2, and 3 prohibit U.S. persons from entering into derivatives contracts linked to new debt or new equity issued by the entities subject to the Directives?

372 … On November 28, 2017, OFAC issued General License 1B , which continues to authorize certain transactions involving derivative products that would otherwise be prohibited pursuant to Directives 1, 2, or 3. General License 1B replaced and superseded General License No. 1A, dated September 12,… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence