Frequently Asked Questions

1024. I have a shipment of a certain product(s) listed in Executive Order (E.O.) 14068 en route to the United States that were contracted prior to March 11, 2022. Can I find a new buyer for this shipment, re-direct the shipment to a country other than the United States, or import the product(s) and comply with the import ban?

1024 … Yes. E.O. 14068 prohibits the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; and non-industrial diamonds of Russian Federation origin. It does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments… Read more

1022. What does Executive Order (E.O.) 14068, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” do?

1022 … E.O. 14068 prohibits the following activities: the importation into the United States of the following products of Russian Federation origin: fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds; and any other products of Russian Federation origin as may be… Read more

1027. For the purposes of Executive Order (E.O.) 14068, as amended, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” and associated determinations, what is meant by the terms “Russian Federation origin,” “fish, seafood, and preparations thereof,” “alcoholic beverages,” “unsorted diamonds,” and “non-industrial diamonds”?

1027 … For the purposes of E.O. 14068 , as amended by E.O. 14114, the Office of Foreign Assets Control anticipates publishing regulations defining these terms to include the following: “Russian Federation origin” – see FAQ 1019 . “fish, seafood, and preparations thereof” – articles defined at… Read more

1028. Does the U.S. dollar-denominated banknote export ban imposed by Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” prohibit sending noncommercial, personal remittances denominated in U.S. dollars to the Russia Federation (or to individuals ordinarily resident in the Russia Federation)?

1028 … E.O. of March 11, 2022 prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the… Read more

1029. How do the prohibitions of Executive Order (E.O.) 14024 and other Russia-related sanctions impact gold-related transactions or persons participating in the gold market?

1029 … Gold-related transactions involving the Russian Federation may be sanctionable under E.O. 14024 or other Russia-related sanctions authorities. For example, E.O. 14024 authorizes sanctions against: Persons determined to be responsible for or complicit in, or to have directly or indirectly… Read more

939. What does Belarus General License 5 (GL 5), “Authorizing the Wind Down of Transactions Involving Open Joint Stock Company Belarusian Potash Company or Agrorozkvit LLC,” authorize?

939 … GL 5 authorizes, through 12:01a.m. eastern standard time, April 1, 2022, all transactions and activities prohibited by Executive Order (E.O.) 14038 that are ordinarily incident and necessary to the wind down of transactions involving Open Joint Stock Company Belarusian Potash Company (BPC) or… Read more

940. What does Directive 1 under Executive Order (E.O.) 14038 do?

940 … Pursuant to Directive 1 under E .O. 14038 , the following activities by U.S. persons or within the United States are prohibited, except to the extent provided by law or unless licensed or otherwise authorized by the Office of Foreign Assets Control: all transactions in, provision of… Read more

941. Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in dealings in both the primary and secondary markets for new debt with a maturity of greater than 90 days issued on or after December 2, 2021 by the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus?

941 … Yes. … Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in dealings in both the primary and secondary markets for new debt with a maturity of greater than 90 days issued on or after December 2, 2021 by the Ministry of Finance of the Republic of Belarus or the Development… Read more

942. Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in dealings related to debt issued before December 2, 2021 by the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus?

942 … No, so long as the terms of such debt (including the repayment period, the interest rate, and the amount) were contractually agreed to before December 2, 2021 and are not modified on or after December 2, 2021. … Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in dealings… Read more

943. Does the 50 Percent Rule apply to Directive 1 under E.O. 14038?

943 … No. The prohibitions in Directive 1 do not apply to any entity that is owned, directly or indirectly, 50 percent or more by the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus, whether individually or in the aggregate. … Does the 50 Percent… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence