Frequently Asked Questions

962. Can banks process transactions related to activities authorized by General Licenses (GLs) 14, 15, 16, 17, 18, 19, and 20?

962 … Yes. Transactions that are ordinarily incident and necessary to give effect to the activities authorized in General Licenses (GL) 14 , GL 15 , GL 16 , GL 17 , GL 18 , GL 19 , or GL 20 , including clearing, settlement, and transfers through, to, or otherwise involving privately owned and… Read more

963. Can humanitarian organizations ship cash into Afghanistan for use in delivering humanitarian assistance?

963 … Yes, cash shipments to Afghanistan may be authorized under General Licenses (GL) 14 , GL 18 , GL 19 , or GL 20 provided that they are ordinarily incident and necessary to effectuate the activities authorized by the GLs. As with all OFAC GLs, GLs 14, 18, 19, and 20 are “self-executing,”… Read more

972. Do non-U.S. financial institutions have to comply with the prohibitions of Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?

972 … Under the Russia-related CAPTA Directive , U.S. financial institutions are prohibited from the opening or maintaining of a correspondent account or payable-through account for or on behalf of, or from processing of a transaction involving, a foreign financial institution determined to be… Read more

968. What foreign financial institutions are listed in Annex 1 to Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?

968 … Annex 1 to the Russia-related CAPTA Directive identifies Public Joint Stock Company Sberbank of Russia as well as many of its foreign financial institution subsidiaries. The foreign financial institutions listed in Annex 1 have been determined to be subject to the prohibitions of the Russia-… Read more

969. Does OFAC’s 50 Percent Rule apply to foreign financial institutions listed in Annex 1 to Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?

969 … Yes. The prohibitions of the Russia-related CAPTA Directive apply to any foreign financial institution listed in Annex 1 to the Russia-related CAPTA Directive or otherwise determined to be subject to the prohibitions of the Russia-related CAPTA Directive, “or their property or interests in… Read more

970. Are foreign financial institutions (FFIs) located outside of Russia potentially subject to the prohibitions of Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?

970 … Yes. The prohibitions of the Russia-related CAPTA Directive apply to a U.S. financial institution’s opening or maintaining of a correspondent account or payable-through account for or on behalf of, or processing of a transaction involving, any FFI, wherever located outside of the United… Read more

1009. Does Executive Order (E.O.) 14065 block the entire Donetsk and Luhansk oblasts?

1009 … No. E.O. 14065 targets the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”). In… Read more

1167. How does Venezuela General License (GL) 45B differ from Venezuela GL 45A?

1167 … On February 29, 2024, OFAC issued Venezuela GL 45B , “Authorizing Certain Repatriation Transactions Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A.,” which narrowed the scope of transactions previously authorized by GL 45A. GL 45B no longer authorizes… Read more

1169. What is prohibited by the determination “Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14071 (the “Metals Services Determination”)?

1169 … The Metals Services Determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of the following categories of services to any person located in the Russian Federation: warranting… Read more

1170. For the purposes of the determination “Prohibitions Related to Imports of Aluminum, Copper, and Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114, (the “Metals Import Determination”) and the determination “Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14071 (the “Metals Services Determination”), what is meant by the terms “aluminum,” “nickel,” and “copper”?

1170 … For the purposes of the Metals Import Determination and the Metals Services Determination , OFAC anticipates publishing regulations defining “aluminum,” “nickel,” and “copper” to include articles or products defined at the following Harmonized Tariff Schedule of the United States (HTSUS)… Read more

Frequently Asked Questions

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