Frequently Asked Questions

1062. Do the prohibitions imposed by the determinations made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” on September 15, 2022, “Prohibitions Related to Certain Quantum Computing Services,” and on May 19, 2023, “Prohibitions Related to Architecture and Engineering Services,” apply to services provided to a parent company located in the Russian Federation by a U.S. subsidiary?

1062 … Yes. The prohibitions apply to services provided to a company located in the Russian Federation (the “Russian company”) by any U.S. person, including the Russian company’s U.S. subsidiary. Date Updated: May 19, 2023 … Do the prohibitions imposed by the determinations made pursuant to… Read more

1063. Do the prohibitions imposed by the determination made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services” (“the determination”), apply only with respect to the formation of new trusts and companies or do the prohibitions also apply with respect to existing trusts and companies?

1063 … The prohibitions imposed by the determination do not distinguish between new and existing trusts and companies. Under the determination, U.S. persons are prohibited from providing trust and corporate formation services to persons located in the Russian Federation, regardless of whether the… Read more

1069. What does Nicaragua General License (GL) 3 authorize?

1069 … Nicaragua GL 3 authorizes U.S. persons to engage in transactions prohibited by the Nicaragua Sanctions Regulations, 31 CFR part 582 (the NSR), that are ordinarily incident and necessary to the wind down of transactions involving Empresa Nicaraguense de Minas (ENIMINAS), or any entity in… Read more

1070. What does the gold-related determination pursuant to Executive Order (E.O.) 14068 prohibit?

1070 … The determination of June 28, 2022 (as amended by the determination of December 22, 2023) issued pursuant to subsection 1(a)(i)(A) of amended E.O. 14068 , “Prohibitions Related to Imports of Gold of Russian Federation Origin,” prohibits the importation into the United States of gold of… Read more

1071. Can I wind down financial contracts that may involve transactions prohibited pursuant to section (1)(a)(i) of Executive Order (E.O.) 14071 related to the purchase or receipt of debt or equity securities issued by an entity in the Russian Federation?

1071 … Through 12:01 a.m. eastern daylight time, October 20, 2022, Russia-related General License (GL) 45 (this content is no longer available) authorizes all transactions prohibited by section (1)(a)(i) of E.O. 14071 that are ordinarily incident and necessary to the wind down of financial… Read more

1072. What does Russia-related General License (GL) 46 authorize with respect to credit derivative transactions referencing “the Russian Federation”?

1072 … Russia-related GL 46 authorizes transactions otherwise prohibited by section (1)(a)(i) of Executive Order (E.O.) 14071 related to the establishment, administration, participation in, and execution of an auction process, as announced by the EMEA Credit Derivatives Determination Committee, to… Read more

1073. Is Sheremetyevo International Airport blocked as a result of the designation of Alexander Anatolevich Ponomarenko?

1073 … No. OFAC has not designated Sheremetyevo International Airport and, based on information available to OFAC, Sheremetyevo International Airport is not owned 50% or more by blocked persons or otherwise considered the blocked property of Alexander Anatolevich Ponomarenko. … Is Sheremetyevo… Read more

1074. Is EuroChem Group AG blocked as a result of the designation of Andrey Igorevich Melnichenko?

1074 … No. OFAC has not designated EuroChem Group AG and, based on information available to OFAC, EuroChem Group AG is not owned 50% or more by blocked persons or otherwise considered the blocked property of Andrey Igorevich Melnichenko. As a general matter, agricultural and medical trade are not… Read more

1075. Is PhosAgro PJSC blocked as a result of the designation of Andrey Grigoryevich Guryev and Andrey Andreevich Guryev?

1075 … No. OFAC has not designated PhosAgro PJSC and, based on information available to OFAC, PhosAgro PJSC is not owned 50% or more by blocked persons or otherwise considered the blocked property of Andrey Grigoryevich Guryev and Andrey Andreevich Guryev. As a general matter, agricultural and… Read more

1030. What obligations do operators of credit card systems have under the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. part 587 (RuHSR), and the Belarus Sanctions Regulations, 31 C.F.R. part 548 (BSR), with regard to payment cards issued by sanctioned Russian financial institutions?

1030 … Pursuant to the RuHSR and BSR, U.S. persons, including U.S. operators of credit card systems and U.S. acquirers, are prohibited from processing transactions involving certain sanctioned foreign financial institutions, unless exempt or authorized by OFAC. Non-U.S. operators of credit card… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence