Frequently Asked Questions

1159. What transactions does Global Terrorism Sanctions Regulations (GTSR) General License (GL) 27 authorize?

1159 … Wind down transactions: GL 27 authorizes all transactions prohibited by the GTSR that are ordinarily incident and necessary to the wind down of any transaction involving Fly Baghdad through 12:01 a.m. eastern daylight time, March 22, 2024, provided that any payment to Fly Baghdad must be… 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?

1182 … 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… Read more

1183. What authorizations are in place with respect to the Moscow Exchange (MOEX), National Clearing Center (NCC), and Non-Bank Credit Institution Joint Stock Company National Settlement Depository (NSD)?

1183 … On June 12, 2024, OFAC issued Russia-related general licenses (GLs) GL 99 , GL 100 , and amended GL 8J , authorizing certain transactions involving MOEX, NCC, NSD, or any entity in which one of these entities owns, directly or indirectly, individually or in the aggregate, a 50 percent or… Read more

1184. What action did Treasury take on June 12, 2024 with regards to prohibiting certain information technology (IT) and software-related services?

1184 … In line with G7 efforts to disrupt Russia’s defense industry’s reliance on western IT systems, on June 12, 2024, Treasury issued a determination that restricts the provision of certain IT and software-related services to Russia. The determination, “ Prohibition on Certain Information… Read more

1185. What activities are considered prohibited “information technology (IT) consultancy and design services” under the determination, “Prohibition on Certain Information Technology and Software Services,” pursuant to Executive Order (E.O. 14071) (the “IT and Software Services Determination”)?

1185 … IT consultancy and design services include the development and implementation of software, as well as assistance or advice relating to the development and implementation of software, including the supply and installation of bespoke software. However, the retail sale of off-the-shelf… Read more

1186. What activities are considered prohibited “IT support services” and “cloud-based services” for enterprise management software and design and manufacturing software (collectively “Covered Software”) under the determination, “Prohibition on Certain Information Technology and Software Services”, pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”)?

1186 … The IT and Software Services Determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of both IT support services and cloud-based services for the Covered Software to a person… Read more

1187. How does OFAC intend to interpret the following terms in the determination, “Prohibition on Certain Information Technology and Software Services,” pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”): “enterprise management software,” “design and manufacturing software,” “cloud-based services,” “information technology support services,” and “information technology consultancy and design services”?

1187 … OFAC expects to promulgate regulations that define or interpret these terms as follows: The term enterprise management software means the following types of software: enterprise resource planning (ERP), customer relationship management (CRM), business intelligence (BI), supply chain… Read more

1188. Does the determination, “Prohibition on Certain Information Technology and Software Services,” pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”) prohibit U.S. persons from providing services to persons located outside of the Russian Federation that are owned or controlled by persons located in the Russian Federation?

1188 … No, provided that the provision of services is not an indirect export to a person located in the Russian Federation. For the purposes of the IT and Software Services Determination , OFAC interprets the “indirect” provision of the prohibited services to include when the benefit of the… Read more

1160. What changes did the February 15, 2024 regulatory amendment to the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR), make?

1160 … On February 15, 2024, OFAC, in consultation with the Department of State, amended the NKSR to modify an existing general license (GL) and add three new GLs to facilitate humanitarian-related and other activities in North Korea. These changes include: Additional non-governmental organization… Read more

1161. Does the general license for non-governmental organization (NGO) activities at section 510.512 of the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR), authorize NGOs to engage in transactions involving the Government of North Korea?

1161 … Yes, subject to certain conditions and limitations. NGOs may engage in transactions with the Government of North Korea to the extent ordinarily incident and necessary to the activities authorized by § 510.512(a). Such transactions may not include partnerships and partnership agreements… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence