Frequently Asked Questions

915. For purposes of Venezuela General License (GL) 40C, what is liquefied petroleum gas?

915 … For purposes of Venezuela GL 40C , the term liquefied petroleum gas refers to the definition provided by the U.S. Energy Information Administration – a group of hydrocarbon gases, primarily propane, normal butane, and isobutane, derived from crude oil refining or natural gas processing. These… Read more

892. What is the difference between the previous version of Sanctions List Search, and the upgraded version made live to the public on January 25, 2021?

892 … OFAC’s Sanctions List Search application has been available to the public since 2011. Over the years the tool’s userbase grew to a point where the original infrastructure and design for the application could not keep up with demand. In late 2020, OFAC took steps to increase the tool’s… Read more

897. How can a person seek to be removed from an OFAC sanctions list?

897 … Consistent with OFAC regulations, persons may seek to be removed from the Specially Designated Nationals and Blocked Persons List or Other OFAC Sanctions Lists . For information concerning the process for seeking such removal, please refer to OFAC’s Filing a Petition for Removal from an OFAC… Read more

898. What is the effect of Executive Order (E.O.) of June 3, 2021, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People's Republic of China”?

898 … E.O. of June 3, 2021 amends E.O. 13959 by replacing Sections 1 through 5 of E.O. 13959, as amended, and revokes E.O. 13974. In particular, E.O. of June 3, 2021 amends E.O. 13959 to prohibit the purchase or sale by U.S. persons of any publicly traded securities, or any publicly traded… Read more

899. What entities are subject to Executive Order (E.O.) 13959, as amended, and when do the prohibitions against such entities go into effect?

899 … OFAC has published a list on its website containing the names of entities that are subject to the prohibitions of E.O. 13959, as amended, as the Non-SDN Chinese Military-Industrial Complex Companies List (the “NS-CMIC List”), along with additional identifying information where possible. … Read more

900. Executive Order (E.O.) 13959, as amended, authorizes the imposition of certain sanctions on persons who operate or have operated in the surveillance technology sector of the economy of the People’s Republic of China (PRC). For the purposes of E.O. 13959, as amended, how will OFAC target those who operate or have operated in this sector?

900 … Pursuant to E.O. 13959, as amended, OFAC expects to use its discretion to target, in particular, persons whose operations include or support, or have included or supported, (1) surveillance of persons by Chinese technology companies that occurs outside of the PRC; or (2) the development,… Read more

901. Under Executive Order (E.O.) 13959, as amended, what level of due diligence must U.S. persons, including market intermediaries and other participants, undertake to assess whether an underlying purchase or sale is prohibited under E.O. 13959, as amended?

901 … For purposes of assessing whether certain purchases or sales are permissible under E.O. 13959, as amended, U.S. persons — including financial institutions, registered broker-dealers in securities, securities exchanges, and other market intermediaries and participants — may rely upon the… Read more

902. Under Executive Order (E.O.) 13959, as amended, are U.S. persons prohibited from providing investment advisory, investment management, or similar services to a non-U.S. person, including a foreign entity or foreign fund, in connection with the non-U.S. person’s purchase or sale of covered securities of Chinese Military-Industrial Complex Companies (CMICs)?

902 … U.S. persons are not prohibited from providing investment advisory, investment management, or similar services to a non-U.S. person, including a foreign entity or foreign fund, in connection with the non-U.S. person’s purchase or sale of a covered security, provided that the underlying… Read more

903. Do the prohibitions of Executive Order (E.O.) 13959, as amended, apply to U.S. persons who are employed by non-U.S. entities and who, in the ordinary course of their employment, are involved in purchases or sales of Chinese Military-Industrial Complex Companies’ (CMICs) securities on behalf of their non-U.S. employer?

903 … For purposes of E.O. 13959, as amended, U.S. persons employed by non-U.S. entities are not prohibited from being involved in, or otherwise facilitating, purchases or sales related to a covered security on behalf of their non-U.S. employer, provided that such activity is in the ordinary course… Read more

904. Under Executive Order (E.O.) 13959, as amended, are U.S. market makers permitted to facilitate divestment from publicly traded securities of Chinese Military-Industrial Complex Companies (CMICs)?

904 … Yes. U.S. market makers, and non-U.S. market makers who employ U.S. persons, are permitted to engage in activities that are necessary to effect divestiture during the during the 365-day periods in which divestment transactions are permitted or that are not otherwise prohibited under E.O.… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence