Frequently Asked Questions

883. What does Burma General License 4 authorize?

883 … Burma General License (GL) 4 authorizes, subject to certain conditions, all transactions and activities prohibited by Executive Order (E.O.) 14014 , that are ordinarily incident and necessary to the wind down of transactions involving, directly or indirectly, Myanmar Economic Corporation… Read more

884. Do non-U.S. persons, including nongovernmental organizations (NGOs) and foreign financial institutions, risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019 (Caesar Act) for activities that would be authorized under the Syrian Sanctions Regulations (SySR)?

884 … With respect to non-U.S. persons, OFAC will not consider transactions to be “significant” for the purpose of a sanctions determination under the Caesar Act if U.S. persons would not require a specific license from OFAC to participate in such a transaction. See 31 CFR § 542.414. Accordingly… Read more

888. What does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) do?

888 … Pursuant to the Russia-related Sovereign Debt Directive , the following activities by a U.S. financial institution are prohibited: As of June 14, 2021, participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021 by the Central Bank of the Russian… Read more

886. What does Executive Order (E.O.) 14024, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation” do?

886 … E.O. 14024 establishes a new national emergency under which sanctions may be imposed against individuals and entities furthering specified harmful foreign activities of the Russian Federation. This national emergency is separate from the national emergency relating to the crisis in Ukraine,… Read more

887. Are persons identified pursuant to Executive Order (E.O.) 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy blocked pursuant to E.O. 14024?

887 … Persons identified pursuant to E.O. 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy are not subject to prohibitions under E.O. 14024 unless those persons are also sanctioned pursuant to E.O. 14024. For more… Read more

889. Does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) prohibit participation in the secondary market for bonds issued by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation?

889 … Yes (see FAQ 888 and FAQ 965 ). Date Updated: February 22, 2022 … Does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) prohibit participation in the secondary market for bonds… Read more

890. Prior to June 14, 2021, are U.S. financial institutions prohibited from participating in the primary market for ruble or non-ruble denominated bonds issued by, or lending ruble or non-ruble denominated funds to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation?

890 … Even prior to June 14, 2021, “U.S. banks” were prohibited from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign (including the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of… Read more

891. Does the 50 Percent Rule apply to Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive)?

891 … No. The prohibitions of the Russia-related Sovereign Debt Directive apply only to bonds issued by, or loans made to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation. The prohibitions of the… Read more

340. What should I do if I am unsure whether an item or service is covered by 31 CFR § 560.540?

340 … If you require assistance interpreting the authorizations contained in 31 CFR § 560.540 and how they apply to your situation, please contact OFAC’s Compliance hotline or submit a request for interpretive guidance at the OFAC License Application Page . Date Updated: May 16, 2024 … What should… Read more

341. May a non-U.S. person export, reexport, or provide to Iran hardware or software that is subject to Commerce's Export Administration Regulations (EAR) pursuant to 31 CFR § 560.540?

341 … Yes. For purposes of the authorities administered by OFAC, 31 CFR § 560.540 authorizes the exportation, reexportation, or provision of certain hardware and software subject to the EAR by non-U.S. persons outside the United States. See 31 CFR § 560.540(a)(2)(i) and (a)(3). For example, a… Read more

Frequently Asked Questions

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