Frequently Asked Questions

1126. Under Executive Order (E.O.) 14024, "Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation," any person determined to operate or have operated in certain sectors of the Russian Federation economy may be blocked. How is OFAC defining those sectors?

1126 … Section 1(a)(i) of E.O. 14024 imposes sanctions with respect to any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, to operate or have operated in the technology sector or the defense and related materiel sector of the Russian Federation… Read more

174. What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “owned or controlled by the government of a foreign country,” “food, medicine, and medical devices,” “foreign financial institution,” “Iranian financial institution,” “significantly reduced,” and “whether the price and supply of petroleum and petroleum products produced in countries other than Iran is sufficient”?

174 … "significant financial transaction" The Iranian Financial Sanctions Regulations (IFSR), which implement section 104(c) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), identify factors to be used in determining what is significant (as it relates to… Read more

974. What Russian financial institutions were blocked in February 2022 pursuant to Executive Order (E.O.) 14024, and what activities are prohibited as a result?

974 … On February 22, 2022, the Office of Foreign Assets Control (OFAC) designated specified Russian financial institutions pursuant to E.O. 14024 , including the State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), Promsvyazbank Public Joint Stock Company, and… Read more

259. What can a foreign financial institution (FFI) do with the funds resulting from the import of Iranian-origin goods or services once the funds are credited to an account? Can funds be transferred to other accounts?

259 … Section 504 of the TRA requires that, in order for a sanctionable transaction to fall within the bounds of the significant reduction exception , any funds owed to Iran as a result of the bilateral trade transaction must be credited to an "account located in the country with primary… Read more

370. What do the prohibitions in Directives 1 and 2 mean? Are they blocking actions?

370 … The sectoral sanctions imposed on specified persons operating in sectors of the Russian economy identified by the Secretary of the Treasury were done under Executive Order 13662 through Directives issued by OFAC pursuant to its delegated authorities. Directive 1, as amended on September 29,… Read more

984. What does Directive 3 under Executive Order (E.O.) 14024, "Prohibitions Related to New Debt and Equity of Certain Russia-related Entities" (Russia-related Entities Directive) prohibit?

984 … The Russia-related Entities Directive prohibits certain dealings by U.S. persons or within the United States in new debt of longer than 14 days maturity or new equity of Russian entities determined to be subject to the prohibitions of the directive or their property or interests in property.… Read more

931. 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 Afghanistan-related General Licenses (GLs) 14, 15, 16, or 20?

931 … No. Non-U.S. persons may engage in or facilitate transactions that would be authorized for U.S. persons under Afghanistan-related GLs 14 , 15 , 16 , 17 , 18 , 19 , or 20 without exposure to sanctions under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign… Read more

978. For transactions authorized under Russia-related General Licenses (GL) 6D, 7A, or GL 115B what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024?

978 … GLs 6D , 7A , or 115B do not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of entities subject to the prohibitions of Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through… Read more

1017. Does Russia-related General License (GL) 8L remain valid following the issuance of Executive Order (E.O.) 14066, "Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine"?

1017 … Yes. GL 8L , which authorizes the wind-down of energy related transactions involving specified Russian financial institutions, remains in effect until 12:01 a.m. eastern daylight time, March 12, 2025, unless renewed. However, GL 8L does not authorize any transactions prohibited by E.O. 14066… Read more

825. How can parties participate in the Swiss Humanitarian Trade Arrangement (SHTA) to export humanitarian goods to Iran?

825 … The SHTA is overseen by Switzerland's State Secretariat for Economic Affairs (SECO) and intended for use by U.S. and non-U.S. persons domiciled in Switzerland. Exporters within Swiss jurisdiction may reach out to SECO at SHTA@seco.admin.ch for further details on requirements and instructions… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence