Frequently Asked Questions

902 … U.S. persons are not prohibited from providing investment advisory, investment management, or similar services to a non-U.S. person, including a foreign entity or foreign fund, in connection with the non-U.S. person’s purchase or sale of a covered security, provided that the underlying… Read more

903 … For purposes of E.O. 13959, as amended, U.S. persons employed by non-U.S. entities are not prohibited from being involved in, or otherwise facilitating, purchases or sales related to a covered security on behalf of their non-U.S. employer, provided that such activity is in the ordinary course… Read more

904 … Yes.  U.S. market makers, and non-U.S. market makers who employ U.S. persons, are permitted to engage in activities that are necessary to effect divestiture during the during the 365-day periods in which divestment transactions are permitted or that are not otherwise prohibited under E.O.… Read more

905 … No.  The prohibitions of E.O. 13959, as amended, apply only with respect to certain purchases or sales of publicly traded securities of entities listed on the NS-CMIC List.  E.O. 13959, as amended, does not prohibit activity with entities listed on the NS-CMIC List that is unrelated to such… Read more

912 … Belarus GL 3 authorizes transactions and activities with the State Security Committee of the Republic of Belarus (the Belarusian KGB) that are necessary and ordinarily incident to requesting, receiving, utilizing, paying for, or dealing in certain licenses and authorizations for the… Read more

913 … No.  Belarus GL 3 does not authorize the exportation, reexportation, or provision of any goods, technology, or services to the Belarusian KGB or any other blocked person, except for the limited purposes of complying with rules and regulations administered by, and certain actions and… Read more

914 … No. Non-U.S. persons would not risk exposure under U.S. sanctions for engaging in activities or facilitating transactions or payments for such activities that would be authorized for U.S. persons pursuant to Venezuela GL 40C . … Do non-U.S. persons risk exposure to U.S. sanctions for engaging… Read more

915 … For purposes of Venezuela GL 40C , the term liquefied petroleum gas refers to the definition provided by the U.S. Energy Information Administration – a group of hydrocarbon gases, primarily propane, normal butane, and isobutane, derived from crude oil refining or natural gas processing. These… Read more

916 … E.O. of August 9, 2021 expands the scope of the national emergency pertaining to Belarus declared in E.O. 13405, “Blocking Property of Certain Persons Undermining Democratic Processes or Institutions in Belarus ,” to provide additional authorities under which sanctions may be imposed against… Read more

917 … No.   E.O. of August 9, 2021 authorizes the imposition of blocking sanctions on persons operating in certain identified sectors of the Belarus economy, including the defense and related materiel sector, security sector, energy sector, potassium chloride (potash) sector, tobacco products… Read more