Frequently Asked Questions

1198. In light of the designation of Shreya Life Sciences Private Limited (Shreya), are U.S. persons authorized to engage in transactions related to pharmaceutical and other humanitarian-related goods involving Shreya and its subsidiaries?

1198 … Yes. As a general matter, humanitarian trade is not the target of U.S. sanctions. OFAC has issued Russia-related General License (GL) 6D , which authorizes, among other things, certain transactions related to the production, manufacturing, sale, transport, or provision of medicine and… Read more

1199. Can a claim be paid under a policy issued to a blocked individual or entity if the payment is to an innocent third-party (for example, the injured party in an automobile accident)?

1199 … The insurance company should contact OFAC for additional guidance. OFAC will work with you on the specifics of the case. Although authorizing payments to blocked persons is rarely aligned with the U.S. foreign policy and national security objectives of OFAC sanctions, circumstances may weigh… Read more

1200. If a non-sanctioned person files a claim with their insurance company for a loss caused by a blocked person, such as a designated terrorist organization, is the insurance company permitted to pay the claim?

1200 … OFAC is aware that insurers at times receive claims from non-sanctioned persons in non-comprehensively sanctioned jurisdictions for losses caused by individuals or entities on OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List). For example, a U.S. insurance company… Read more

1201. What authorizations exist for diplomatic or consular missions operating in or outside of Russia and Russian diplomatic or consular missions operating abroad?

1201 … The Office of Foreign Assets Control (OFAC) has issued several authorizations related to U.S. and third-country diplomatic or consular missions operating in or outside of Russia and Russian diplomatic or consular missions operating abroad. Russian Diplomatic or Consular Missions, Wherever… Read more

1202. Following the November 21, 2024 designation of Russian financial institutions, Treasury has now designated a significant number of financial institutions in Russia. Will this negatively impact the processing of personal, non-commercial remittances to or from Russia?

1202 … No. Treasury's sanctions target Russian financial institutions that have continued to help Russia gain access to the critical goods it needs to prosecute its war in Ukraine. As a general matter, personal, non-commercial remittances are not the target of sanctions imposed by the United States… 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

1214. Does the determination of January 10, 2025, made pursuant to Executive Order (E.O.) 14024 (the "January 2025 Energy Sector Determination") mean that all persons that operate or have operated in this sector of the Russian Federation economy are sanctioned by OFAC?

1214 … No. 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

1215. Why did OFAC issue General License (GL) 26 ("Transactions Authorized Pursuant to the Russian Harmful Foreign Activities Sanctions Regulations") in the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589 (URSR)?

1215 … GL 26 applies to transactions involving specified persons identified in the Annex to GL 26, who are designated under both the URSR and the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR). The purpose of GL 26 is to ensure that transactions authorized or… Read more

1217. I am a U.S. service provider. Following the January 10, 2025 determinations under Executive Order (E.O.) 14024 and E.O. 14071 (the Energy Sector Determination and Petroleum Services Determination, respectively), am I still authorized to provide certain services relating to the maritime transport of Russian crude oil and Russian petroleum products to a non-sanctioned person operating in the energy sector of the Russian economy, so long as the crude oil or petroleum products are purchased at or below the price cap?

1217 … Yes, as long as the provision of services does not involve an entity blocked pursuant to E.O. 14024 and is not otherwise prohibited by OFAC sanctions. The price cap policy does not authorize transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence