Frequently Asked Questions

396. How do I know when a name has been added, changed, or removed on the Sectoral Sanctions Identifications (SSI) List?

396 … The SSI List available on OFAC's website is the latest version of the list and contains the most updated information on entities determined to be subject to one or more of the Directives. OFAC also maintains "changes files" that record all significant changes to the SSI List. Any addition,… Read more

404. Is the term "new equity" in Directive 1 limited to equity that is issued by an SSI entity after the sanctions effective date or would equity purchased or acquired by an SSI entity from a third party after the sanctions effective date be considered new equity?

404 … The equity prohibitions in Directive 1 pertain to equity issued directly or indirectly, by an SSI entity on or after the sanctions effective date. Directive 1 does not prohibit U.S. persons from dealing with an SSI entity as counterparty to transactions involving equity issued by a non-… Read more

405. Does the prohibition on “otherwise dealing in new debt” of longer than the applicable tenor specified in the relevant Directive of SSI entities, their property, or their interests in property prohibit dealing in debt with maturity that exceeds the applicable authorized tenor in which the SSI entity is not directly or indirectly the borrower?

405 … Directives 1, 2, and 3 only prohibit U.S. persons from dealing in new debt that is issued by a person subject to the relevant Directive (and only where the debt has a tenor that exceeds the applicable tenor specified in the relevant Directive). Directives 1, 2, and 3 do not prohibit U.S.… Read more

406. Does the prohibition on dealing in new equity of entities subject to Directive 1 apply to transactions in which those entities are not the issuer of the equity?

406 … U.S. persons are not prohibited from dealing in new equity with an entity subject to Directive 1 if the entity is not the issuer of the equity. For instance, U.S. persons are not prohibited from transacting with an entity subject to Directive 1 in support of new equity where the entity… Read more

407. May a U.S. person consent to a replacement of its participation by a non-U.S. person in a long-term loan facility that was extended to a person subject to Directives 1, 2, or 3 prior to the sanctions effective date?

407 … A U.S. person is not prohibited by Directives 1, 2, or 3 from engaging in transactions necessary to exit or replace its participation in a long-term loan facility that was extended to an SSI entity prior to the sanctions effective date. This would not constitute dealing in new debt. U.S.… Read more

408. Is a U.S. person permitted under Directives 1, 2, or 3 to extend credit for longer than the applicable tenor specified in the relevant Directive to a non-sanctioned party for the purpose of purchasing goods or services from a person subject to Directives 1, 2, or 3?

408 … Directives 1, 2, and 3 do not prohibit U.S. persons from extending credit for longer than the applicable tenor specified in the relevant Directive to non-sanctioned parties for the purpose of purchasing goods or services from an SSI entity, so long as the SSI entity is not the indirect… Read more

409. If a person determined to be subject to Directives 1, 2, or 3 is a borrower under a short-term facility created after the sanctions effective date, does the facility become prohibited if the SSI entity borrower makes successive short-term borrowings that cumulatively add up to more than the applicable tenor specified in the relevant Directive (e.g., it borrows $100 million with a 10-day maturity, then at the end of the 10 days, the debt “rolls over”)?

409 … Two conditions must be met for short-term facilities created after the sanctions effective date to be permissible. As long as (1) each individual disbursement has a maturity of no longer than the applicable tenor specified in the relevant Directive and the disbursement is paid back in full… Read more

410. Are U.S. persons prohibited from entering into new contracts after the sanctions effective date with persons subject to Directives 1, 2, or 3 that provide payment terms to the SSI entities of greater than the applicable tenor specified in the relevant Directive? For instance, if a U.S. person agrees to sell shares or assets to an SSI entity in a corporate transaction that becomes effective on or after the sanctions effective date, is the U.S. person prohibited from agreeing to deferred purchase payments, even if no interest is involved, that may be paid more than the permissible number of days later by the SSI entity?

410 … Directives 1, 2, and 3 prohibit new extensions of credit to SSI entities of greater than the applicable tenor specified in the relevant Directive, and these prohibitions include deferred purchase agreements extending payment terms of longer than the applicable tenor specified in the relevant… Read more

411. What does the prohibition contained in Directive 3 under Executive Order 13662 mean? What is the scope of prohibited services?

411 … OFAC issued Directive 3 , introducing new prohibitions on all transactions in, provision of financing for, and other dealings in new debt of longer than 30 days maturity of persons determined to be subject to the Directive, their property, or their interests in property. Transactions by U.S.… Read more

412. What do the prohibitions contained in Directive 4 mean? What is the scope of prohibited services?

412 … Directive 4, as amended on October 31, 2017 in accordance with CAATSA , imposes two prohibitions on the provision, exportation, or reexportation of goods, services (except for financial services), or technology for certain activities involving persons subject to Directive 4, their property,… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence