Frequently Asked Questions

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

865. May market intermediaries and other participants facilitate divestment from publicly traded securities of Chinese Military-Industrial Complex Companies (CMICs), including divestment by investment fund managers?

865 … Yes. Market intermediaries, including market makers, and other participants may engage in ancillary or intermediary activities that are necessary to effect divestiture during the relevant wind-down periods or that are not otherwise prohibited under E.O. 13959, as amended. Purchases or sales… Read more

871. What are the compliance obligations of securities exchanges operated by U.S. persons with respect to Executive Order (E.O.) 13959, as amended?

871 … Consistent with FAQ 865 , which clarifies that market intermediaries and other participants may engage in ancillary or intermediary activities that are necessary to effect divestiture during the relevant wind-down periods or that are not otherwise prohibited under E.O. 13959, as amended,… Read more

883. What does Burma General License 4 authorize?

883 … Burma General License (GL) 4 authorizes, subject to certain conditions, all transactions and activities prohibited by Executive Order (E.O.) 14014 , that are ordinarily incident and necessary to the wind down of transactions involving, directly or indirectly, Myanmar Economic Corporation… Read more

888. What does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) do?

888 … Pursuant to the Russia-related Sovereign Debt Directive , the following activities by a U.S. financial institution are prohibited: As of June 14, 2021, participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021 by the Central Bank of the Russian… Read more

886. What does Executive Order (E.O.) 14024, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation” do?

886 … E.O. 14024 establishes a new national emergency under which sanctions may be imposed against individuals and entities furthering specified harmful foreign activities of the Russian Federation. This national emergency is separate from the national emergency relating to the crisis in Ukraine,… Read more

887. Are persons identified pursuant to Executive Order (E.O.) 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy blocked pursuant to E.O. 14024?

887 … Persons identified pursuant to E.O. 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy are not subject to prohibitions under E.O. 14024 unless those persons are also sanctioned pursuant to E.O. 14024. For more… Read more

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

1203 … GL 115B 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… Read more

1204. On December 27, 2024, OFAC designated Bidzina Ivanishvili (Ivanishvili) pursuant to Executive Order (E.O.) 14024. Can I continue to engage in transactions or other dealings with entities owned by Ivanishvili that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

1204 … Yes. Although transactions or other dealings involving Ivanishvili are generally prohibited as a result of OFAC's designation, OFAC concurrently issued General License (GL) 116 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ivanishvili provided… Read more

1213. For the purposes of the determination of January 10, 2025 made pursuant to Executive Order (E.O.) 14024 (the "January 2025 Energy Sector Determination"), what is meant by the term "energy sector of the Russian Federation economy"?

1213 … On January 10, 2025, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the energy sector of the Russian… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence