Frequently Asked Questions

582. I am located outside of the United States and seek to export goods from a third-country location in connection with activity for the maintenance or wind down of contracts or agreements with an entity listed on General License 12B (or any other entity in which a listed entity in 12B owns, directly or indirectly, a 50 percent or greater interest). Are such exports excluded from the authorization in General License 12B or otherwise subject to section 10 of SSIDES, as amended by section 228 of CAATSA, or section 5 of UFSA, as amended by section 226 of CAATSA?

582 … No. Although General License 12B does not authorize the exportation of goods from the United States, paragraph (d)(4) of General License 12B does not similarly apply to the exportation of goods from a third country to another location. … I am located outside of the United States and seek to… Read more

583. Why is OFAC issuing General License 12B, and what new activity does it authorize?

583 … OFAC issued General License 12B to address difficulties blocked U.S. persons are having accessing funds needed for authorized wind-down and maintenance activities. General License 12B explicitly permits originating and intermediary U.S. financial institutions to process funds transfers that… Read more

585. May U.S. persons do business with a foreign company in which blocked persons hold, individually or in the aggregate, a less than 50 percent interest? Are foreign persons, including foreign financial institutions, subject to sanctions 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 doing business with a foreign company in which blocked persons hold, individually or in the aggregate, a less than 50 percent interest?

585 … If one or more blocked persons does not hold, individually or in the aggregate, a 50 percent or greater interest in a foreign company, the foreign company is not itself blocked by virtue of OFAC’s 50 percent rule , and U.S. persons generally are not prohibited from engaging in transactions… Read more

586. What transactions are authorized under wind-down General License (GL) 15L?

586 … GL 15L superseded GL 15K on April 25, 2022. While GL 15K authorized certain transactions and activities that were ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements involving GAZ Group, or any entity in which GAZ Group owns,… Read more

587. Under what circumstances can OFAC give further sanctions relief to GAZ Group or any other entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest?

587 … Consistent with OFAC regulations, parties may be removed by demonstrating a change in the circumstances that led to their designation. In the case of GAZ Group, absent other adverse information and consistent with the facts and circumstances of any petition for delisting, the path for the… Read more

589. Will foreign persons be subject to sanctions under the Section 5 of the Ukraine Freedom Support Act (UFSA) or Section 10 of the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act (SSIDES), as amended, respectively, by Sections 226 or Section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) for engaging in activities with GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest?

589 … As described in FAQs 542 , 545 , 574 , and 579 , a transaction will not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES , as amended by section 228 of CAATSA , and section 5 of UFSA , as amended by section 226 of CAATSA, if a U.S. person… Read more

590. I am a foreign person that seeks to pay GAZ Group or another entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest for goods or services connected with activities authorized by General License (GL) 15L. Am I required to deposit payment into a blocked account at a U.S. financial institution in order for my payment not to be considered “significant” for purposes of section 10 of SSIDES, as amended by section 228 of CAATSA, or section 5 of UFSA, as amended by section 226 of CAATSA?

590 … No. U.S. persons may engage in activities authorized by GL 15L that occur on or after May 22, 2018, except for activities involving blocked persons other than GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) without making associated… Read more

591. I am a U.S. person that seeks to supply goods to GAZ Group. Am I permitted to export those goods from the United States to GAZ Group pursuant to General License (GL) 15L?

591 … GL 15L authorizes transactions and activities that are ordinarily incident and necessary to the wind down of transactions involving GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest), including exports. Any exports to GAZ Group must be… Read more

592. Does General License (GL) 15L authorize U.S. persons to receive regularly scheduled payments of principal and interest from GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest)? Does GL 15L authorize U.S. persons to receive accelerated payments or voluntary prepayment pursuant to the terms of such loan or bond?

592 … Yes, GL 15L authorizes U.S. persons to receive regularly scheduled payments of principal and interest from GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) only to the extent such transactions are ordinarily incident and necessary to… Read more

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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence