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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence