Frequently Asked Questions

1117. My company provides goods or services to, or engages in trade with, persons that operate or have operated in the metals and mining sector of the Russian Federation economy. Does my company risk being sanctioned by OFAC?

1117 … The determination made on February 24, 2023 pursuant to Executive Order (E.O.) 14024 authorizes sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy. Non-U.S. persons may also be exposed to sanctions for activities… 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

1121. What does Global Magnitksy General License 7, Authorizing Certain Transactions Involving Tabacalera del Este, S.A. or Tabacos USA Inc. Pursuant to the Tobacco Master Settlement Agreement, authorize?

1121 … Global Magnitsky General License 7 authorizes certain transactions involving the blocked entities Tabacos USA Inc. (Tabacos) and Tabacalera del Este S.A. (Tabesa) (or any entity in which Tabesa or Tabacos owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater… Read more

1134. What is the humanitarian channel in Qatar?

1134 … The humanitarian channel in Qatar (HC) was established to further facilitate the flow of humanitarian assistance to the people of Iran consistent with the U.S. government’s longstanding support for humanitarian trade. Similar to humanitarian channels established under previous… Read more

1135. How can companies participate in the humanitarian channel in Qatar to export humanitarian goods to Iran?

1135 … Financial institutions participating in the humanitarian channel in Qatar (HC) have received specific guidance from the U.S. government. Companies interested in participating in transactions under the HC should coordinate directly with the Qatari International Media Office at info@imo.gov.… Read more

1136. Can U.S. persons purchase bonds issued by the Government of Venezuela or Petróleos de Venezuela, S.A. (PdVSA) prior to August 25, 2017 on the secondary market?

1136 … Yes. On October 18, 2023, OFAC issued amended General Licenses (GLs) 3I and 9H , to remove the restriction that any divestment by U.S. persons of holdings in GL 3I Bonds (as defined in GL 3I and FAQ 662 ) or PdVSA Securities (as defined in GL 9H and FAQ 661 ) must be to non-U.S. persons. GL… Read more

1137. For purposes of General License (GL) 45B, “Authorizing Certain Repatriation Transactions Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A.,” what countries are included in the “Western Hemisphere”?

1137 … For the purposes of GL 45B, OFAC considers the term “Western Hemisphere” to mean those countries and areas identified by the Department of State on its website as comprising the Western Hemisphere. Please see: Bureau of Western Hemisphere Affairs - United States Department of State. Date… Read more

1138. What does Directive 1 under Executive Order 14014, “Prohibitions Related to Financial Services to or for the Benefit of Myanma Oil and Gas Enterprise” (MOGE Financial Services Directive) prohibit?

1138 … Pursuant to the MOGE Financial Services Directive , the following activities by a U.S. person are prohibited on or after December 15, 2023: the provision, exportation, or rexportation, directly or indirectly, of financial services to or for the benefit of Myanma Oil and Gas Enterprise (MOGE… Read more

1139. Does the 50 Percent Rule apply to Directive 1 under Executive Order 14014, “Prohibitions Related to Financial Services to or for the Benefit of Myanma Oil and Gas Enterprise” (MOGE Financial Services Directive)?

1139 … Yes. The prohibitions in the MOGE Financial Services Directive apply to MOGE “or its property or interests in property,” including any entity, such as a subsidiary or joint venture, that is 50 percent or more owned, directly or indirectly, by MOGE, except to the extent otherwise provided by… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence