Frequently Asked Questions

1114. What actions were taken on February 24, 2023 related to the metals and mining sector of the Russian Federation economy?

1114 … On February 24, 2023, the Director of OFAC, in consultation with the Department of State, issued a sectoral determination pursuant to Executive Order (E.O.) 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the metals and… Read more

1115. For the purposes of the determination of February 24, 2023 made pursuant to Executive Order (E.O.) 14024, what is meant by the term “metals and mining sector of the Russian Federation economy”?

1115 … For the purposes of the determination of February 24, 2023 made pursuant to E.O. 14024 , OFAC anticipates publishing regulations defining the term “metals and mining sector of the Russian Federation economy” to include any act, process, or industry of extracting, at the surface or… Read more

1116. Does the determination of February 24, 2023 made pursuant to Executive Order (E.O.) 14024 with regard to the metals and mining sector of the Russian Federation economy mean that all persons that operate or have operated in this sector of the Russian Federation economy are sanctioned by OFAC?

1116 … No. The Director of OFAC, in consultation with the State Department, has 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 metals and mining sector of the Russian Federation economy.… Read more

1119. Does General License (GL) O authorize all wind-down transactions for any vessel that was blocked on March 2, 2023? What if the vessel contains Iranian-origin merchandise?

1119 … Iran GL O authorizes U.S. persons to wind down all transactions otherwise prohibited by section 5 of Executive Order 13846 involving any vessel blocked as part of the March 2, 2023 designation (“blocked vessels”), subject to certain conditions. This includes, among other activities, the… Read more

1120. Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions that U.S. persons would be authorized to engage in under Iran General License (GL) O?

1120 … No. Non-U.S. persons generally do not risk exposure to sanctions for engaging in activities or facilitating transactions for such activities that would be authorized for U.S. persons pursuant to GL O . Non-U.S. persons unable to wind down transactions in accordance with Iran GL O before 12… Read more

938. What early-recovery-related transactions and activities are nongovernmental organizations (NGOs) authorized to engage in pursuant to the general license (GL) at § 542.516 of the Syrian Sanctions Regulations (SySR), as amended on June 5, 2024?

938 … The GL at § 542.516 of the SySR authorizes NGOs to engage in activities in support of certain non-commercial activities in Syria, including: humanitarian projects to meet basic human needs; democracy-building; education; non-commercial development projects directly benefitting the Syrian… Read more

939. What does Belarus General License 5 (GL 5), “Authorizing the Wind Down of Transactions Involving Open Joint Stock Company Belarusian Potash Company or Agrorozkvit LLC,” authorize?

939 … GL 5 authorizes, through 12:01a.m. eastern standard time, April 1, 2022, all transactions and activities prohibited by Executive Order (E.O.) 14038 that are ordinarily incident and necessary to the wind down of transactions involving Open Joint Stock Company Belarusian Potash Company (BPC) or… Read more

940. What does Directive 1 under Executive Order (E.O.) 14038 do?

940 … Pursuant to Directive 1 under E .O. 14038 , the following activities by U.S. persons or within the United States are prohibited, except to the extent provided by law or unless licensed or otherwise authorized by the Office of Foreign Assets Control: all transactions in, provision of… Read more

941. Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in dealings in both the primary and secondary markets for new debt with a maturity of greater than 90 days issued on or after December 2, 2021 by the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus?

941 … Yes. … Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in dealings in both the primary and secondary markets for new debt with a maturity of greater than 90 days issued on or after December 2, 2021 by the Ministry of Finance of the Republic of Belarus or the Development… Read more

942. Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in dealings related to debt issued before December 2, 2021 by the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus?

942 … No, so long as the terms of such debt (including the repayment period, the interest rate, and the amount) were contractually agreed to before December 2, 2021 and are not modified on or after December 2, 2021. … Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in dealings… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence