Frequently Asked Questions

616 … All property and interests in property of NIOC and NICO subject to U.S. jurisdiction are already blocked pursuant to E.O. 13599, and U.S. persons are prohibited from all dealings with these entities. E.O. 13846 reestablishes the authority previously contained in E.O. 13622 to sanction FFIs… Read more

617 … Yes. As in E.O. 13622, E.O. 13846 defines NIOC and NICO to include any entity owned or controlled by, or operating for or on behalf of, NIOC and NICO. … E.O. 13846 targets transactions between foreign financial institutions and NIOC and NICO. What about a NIOC or NICO subsidiary? Are… Read more

618 … No. Section 10 of E.O. 13846 maintains the exceptions previously provided for in E.O. 13622 and E.O. 13645, as well as in subsection 603(a) of the TRA and section 1254 of IFCA, for the pipeline project to supply natural gas from the Shah Deniz gas field in Azerbaijan to Europe and Turkey. …… Read more

619 … Yes. To the extent a financial institution is involved, that financial institution could be sanctioned under E.O. 13846 for a barter arrangement, on or after November 5, 2018, related to the purchase or acquisition of petroleum, petroleum products, or petrochemical products from Iran. In… Read more

574 … Section 228 of CAATSA amends SSIDES by inserting a mandatory sanctions provision on foreign persons that Treasury determines, inter alia, knowingly facilitate significant transactions, including deceptive or structured transactions, for or on behalf of any person subject to U.S. sanctions… Read more

575 … The purpose of General License 14 is to allow United Company RUSAL PLC (RUSAL) or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest, to continue maintenance or wind down activities until October 23, 2018. Although all funds blocked prior to 12:01 a… Read more

576 … Consistent with OFAC regulations, parties may be removed by demonstrating a change in the circumstances that led to their designation. In the case of RUSAL, absent other adverse information and consistent with the facts and circumstances of any petition for delisting, the path for the United… Read more

577 … No. All accounts or other property of RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest blocked as of April 23, 2018 remain blocked, except for the use in maintenance and wind-down activities described in General License 14. U.S. persons,… Read more

578 … General License 12A was amended to reflect the authorization in General License 14 . Specifically, U.S. persons were no longer required to place into a blocked account payments to or for RUSAL, or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest,… Read more

579 … As described in FAQs 542 , 545 , and 574 , a transaction will not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES , as amended by section 228 of CAATSA , and section 5 of UFSA , as amended by section 226 of CAATSA, if U.S. persons would not… Read more