Frequently Asked Questions

1260. Does the requirement in certain Venezuela General Licenses (e.g., 46C, 47A, 48B, 50B, 51B, 52A, and 54A) that the terms of contracts be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States mean that U.S. law must govern all aspects of the underlying activity?

No. Certain Venezuela general licenses (GLs) require that any contract for transactions authorized by the GL with the Government of Venezuela or certain other covered entities (e.g., Petróleos de Venezuela, S.A. in GL 52A or CVG Compañía General de Minería de Venezuela CA in GL 51B ) specify that… Read more

967. What does Directive 2 under Executive Order (E.O.) 14024, "Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions" (Russia-related CAPTA Directive) prohibit?

The Russia-related CAPTA Directive prohibits U.S. financial institutions from: (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive;… Read more

1216. What action has Treasury taken with regard to the provision of petroleum services to Russia?

In line with G7 efforts to reduce Russian revenues from energy, on January 10, 2025, Treasury issued a determination pursuant to Executive Order (E.O.) 14071 prohibiting petroleum services to Russia. See The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition on… Read more

1182. Are foreign financial institutions (FFIs) subject to sanctions risk for providing all financial services involving persons blocked pursuant to Executive Order (E.O.) 14024, as amended? What about agricultural, medical, and other transactions authorized by OFAC General Licenses?

Treasury remains focused on counteracting activity that involves sanctions evasion or third-country support to Russia's military-industrial base. At the same time, legitimate humanitarian activity and agricultural and medical trade are not the target of our sanctions. Accordingly, FFIs may continue… Read more

1117. My company provides goods or services to, or engages in trade with, persons that operate or have operated in the metals and mining sector of the Russian Federation economy. Does my company risk being sanctioned by OFAC?

The determination made on February 24, 2023 pursuant to Executive Order (E.O.) 14024 authorizes sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy. Non-U.S. persons may also be exposed to sanctions for activities with… Read more

999. What authorizations exist for entities subject to Directive 4 under Executive Order (E.O.) 14024, "Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation," as amended (Russia-related Sovereign Transactions Directive)?

OFAC issued Russia-related General License (GL) 132 to authorize transactions involving the Paks II civil nuclear power plant project in Hungary, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive.… Read more

978. For transactions authorized under Russia-related General Licenses (GL) 6D, 7A, 115D, or 132, what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024?

GLs 6D , 7A , or 115D , or 132 do not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of entities subject to the prohibitions of Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through… Read more

1203. What does General License (GL) 115D ("Authorizing Certain Transactions Related to Civil Nuclear Energy") authorize with respect to civil nuclear energy-related payments?

GL 115D generally authorizes certain transactions related to civil nuclear energy involving certain entities that are sanctioned pursuant to Executive Order 14024. Civil nuclear energy means the following activities when undertaken solely to maintain or support civil nuclear energy projects and… Read more

1011. My U.S. bank refused to process a requested payment related to energy despite the authorization in Russia-related General License (GL) 115D under Executive Order (E.O.) 14024. What can I do?

The Office of Foreign Assets Control (OFAC) encourages persons to connect with their financial institution regarding the status of any payment. In addition, persons with questions about engaging in or processing transactions related to GL 115D can contact the OFAC Compliance Hotline . Updated: June… Read more

519. How can I help the Venezuelan people while making sure to abide by the U.S. sanctions?

While E.O. 13884 blocks all property and interests in property of the Government of Venezuela that come into the possession or control of U.S. persons or U.S. jurisdiction, the Venezuelan people are not subject to comprehensive U.S. sanctions. Sanctions do not preclude U.S. persons from exporting… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence