Frequently Asked Questions

849. Can a foreign financial institution (FFI) be excluded or removed from the Section 5(b) Report so that sanctions under the Hong Kong Autonomy Act (HKAA) would not apply?

849 … Pursuant to section 5(d)(2) of the HKAA , an FFI may be excluded from the Section 5(b) Report or an update to that report under section 5(e) of the HKAA, or may be removed from the Section 5(b) Report or an update to that report prior to the imposition of sanctions under section 7(a), if the… Read more

850. How does the Treasury Department determine whether a transaction is “significant” for purposes of section 5(b) of the Hong Kong Autonomy Act (HKAA)?

850 … For purposes of implementing section 5(b) of the HKAA , the Secretary of the Treasury may consider the totality of the facts and circumstances when determining whether transactions are “significant.” As a general matter, the Treasury Department may consider some or all of the following… Read more

851. How will the following key terms in section 5(b) of the Hong Kong Autonomy Act (HKAA) be defined: “financial institution” and “knowingly”?

851 … Section 2 of HKAA defines these terms as follows, which OFAC intends to incorporate into relevant regulations: “financial institution” – the term “financial institution” is defined to have the same meaning as a financial institution specified in section 5312(a)(2) of title 31, United States… Read more

817. What is the significance of OFAC’s designations of Rosneft Trading S.A. and TNK Trading International S.A.? Do the E.O. 13850 blocking sanctions on Rosneft Trading S.A. and TNK Trading International S.A. apply to their corporate parent and their affiliates?

817 … On February 18, 2020, OFAC designated Rosneft Trading S.A. pursuant to E.O. 13850 for operating in the oil sector of the Venezuelan economy. Likewise, on March 12, 2020, OFAC designated TNK Trading International S.A. pursuant to E.O. 13850 for operating in the oil sector of the Venezuelan… Read more

818. Is there a wind-down period for transactions involving Rosneft Trading S.A. or TNK Trading International S.A.?

818 … OFAC issued General License(GL) 36A, which authorizes U.S. persons to engage in certain activities prohibited by E.O. 13850 necessary for the wind down of transactions involving Rosneft Trading S.A. or TNK Trading International S.A., or any entity in which Rosneft Trading S.A. or TNK Trading… Read more

819. Is the June 21, 2019 amendment to the Office of Foreign Assets Control (OFAC)'s Reporting, Procedures and Penalties Regulations in effect? Am I required to comply with all requirements of the amended regulations?

819 … Yes, effective June 21, 2019, OFAC amended the Reporting, Procedures and Penalties Regulations, 31 CFR part 501 (RPPR) , to provide updated instructions and incorporate new requirements for parties filing reports on blocked property, unblocked property, or rejected transactions. In addition,… Read more

820. I am required to submit a rejected transaction report to OFAC, but I do not have all the information that is required to be reported pursuant to 31 CFR § 501.604(b). Am I required to collect such information from my counterparty just to complete my rejected transaction report?

820 … OFAC expects U.S. persons and persons otherwise subject to U.S. jurisdiction to provide all information required by Section 501.604(b) of the RPPR that is in the filer’s possession in a rejected transaction report, and generally does not expect reporters to seek further information from… Read more

827. What does Nicaragua-related General License (GL) 2 authorize with respect to the Nicaraguan National Police?

827 … GL 2 authorizes the wind down of transactions involving the Nicaraguan National Police (NNP), including the processing of salary payments from the NNP to its employees, so long as no other blocked persons are involved in the transaction, through 12:01 a.m. eastern daylight time, May 6, 2020.… Read more

828. I want to help with the humanitarian response to public health concerns, including the Coronavirus Disease 2019 (COVID-19) outbreak, in Iran. What can I do to help while remaining compliant with U.S. sanctions?

828 … There are a number of ways consistent with U.S. sanctions to provide humanitarian goods or assistance to the Iranian people in response to public health concerns in Iran, including the COVID-19 outbreak. The making of humanitarian donations to recipients in Iran from the United States or by… Read more

289. How will the following Iran Freedom and Counter-Proliferation Act (IFCA) terms be interpreted: “Iran,” “knowingly,” “significant,” and “transfer”?

289 … As a general matter, we intend to rely, where applicable, on definitions of terms previously included in Treasury regulations. “Iran” The Iranian Financial Sanctions Regulations ( 31 CFR part 561 ) (IFSR) define “Iran” as the Government of Iran and the territory of Iran and any other… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence