Frequently Asked Questions

1151. How does OFAC intend to interpret the following terms in Executive Order (E.O.) 14024, as amended by E.O. 14114: “foreign financial institution,” “Russia’s military-industrial base,” and “significant transaction or transactions”?

1151 … OFAC expects to promulgate regulations that define or interpret these terms as follows: Foreign Financial Institution: As defined in subsection 11(f) of E.O. 14024 , foreign financial institution means any foreign entity that is engaged in the business of accepting deposits, making, granting… Read more

1152. Could foreign financial institutions (FFIs) that engage in transactions in non-USD currencies be sanctioned under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?

1152 … Yes. The prohibitions and targeting authorities of amended section 11 of E.O. 14024 apply with respect to any currency. For example, an FFI that processes a significant transaction denominated in a non-USD local currency for a person blocked pursuant to E.O. 14024 or an FFI that processes… Read more

1154. How does Executive Order (E.O.) 14114 of December 22, 2023 amend E.O. 14068, “Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression”?

1154 … E.O. 14114 of December 22, 2023 amends E.O. 14068 to provide for additional prohibitions on the importation and entry into the United States of certain products. It does so by maintaining the existing E.O. 14068 importation prohibitions in subsection 1(a)(i)(A) and identifying in… Read more

1155. What does the determination of December 22, 2023, “Prohibitions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof,” pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114 of December 22, 2023, (Seafood Determination) prohibit?

1155 … The Seafood Determination issued pursuant to subsection 1(a)(i)(B) of E.O. 14068 , as amended, prohibits the importation and entry into the United States, including importation for admission into a foreign trade zone located in the United States, of salmon, cod, pollock, or crab that was… Read more

1156. I have a shipment of a certain product(s) containing the types of seafood listed in the determination of December 22, 2023 pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114 of December 22, 2023, (Seafood Determination) en route to the United States that was contracted prior to December 22, 2023. Can I complete such import into the United States? Can I find a new buyer for this shipment and/or re-direct the shipment to a country other than the United States?

1156 … Individuals and entities may import the listed types of seafood, for a limited time, into the United States subject to the conditions of General License (GL) 83 . GL 83 authorizes the importation into the United States, through 12:01 a.m. eastern standard time, February 21, 2024, of salmon… 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

1140. In light of the designation of Orka Holding, are U.S. persons authorized to engage in transactions related to the provision of medicine, medical devices, and medical services involving Orka Holding and its subsidiaries?

1140 … Yes. As a general matter, humanitarian trade is not the target of U.S. sanctions. Concurrent with the designation of Orka Holding AD, OFAC issued Western Balkans General License (GL) 3 , which authorizes all transactions involving Orka Holding AD related to: (1) the production,… Read more

1141. Does Venezuela General License (GL) 45B authorize U.S. persons to provide certain services, including refueling services, repair, and maintenance, to blocked Conviasa aircraft that are carrying out flights for the exclusive purpose of repatriating Venezuelan nationals from a third country in the Western Hemisphere to Venezuela?

1141 … Yes. Date updated: March 01, 2024 … Does Venezuela General License (GL) 45B authorize U.S. persons to provide certain services, including refueling services, repair, and maintenance, to blocked Conviasa aircraft that are carrying out flights for the exclusive purpose of repatriating… Read more

1157. For the purposes of the determination of December 22, 2023 pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114 of December 22, 2023, (Seafood Determination) what is meant by the terms “salmon,” “cod,” “pollock,” and “crab”?

1157 … For the purposes of the Seafood Determination , OFAC anticipates publishing regulations defining these terms to include articles defined at the following Harmonized Tariff Schedule of the United States (HTSUS) subheadings: • “Salmon:” articles defined at HTSUS subheadings 0302.13.0013,… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence