Frequently Asked Questions

987. If a U.S. person entered into a revolving credit facility or long-term loan agreement for an entity determined to be subject to Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prior to the relevant sanctions effective date described in the Russia-related Entities Directive, what are the restrictions on drawdowns from that facility? Do all drawdowns and disbursements pursuant to the parent agreement need to carry repayment terms of 14 days or less?

987 … If a U.S. person entered into a long-term credit facility or loan agreement prior to the relevant sanctions effective date described in the Russia-related Entities Directive, drawdowns and disbursements with repayment terms of 14 days or less are permitted. In addition, drawdowns and… Read more

988. Does Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prohibit U.S. persons from engaging in all activities with entities subject to it?

988 … No. The Russia-related Entities Directive prohibits U.S. persons from engaging in only certain activities related to new debt of longer than 14 days maturity or new equity of the entities listed in Annex 1 to the Russia-related Entities Directive, or of entities otherwise determined to be… Read more

989. Does Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prohibit U.S. persons from engaging in dealings related to debt or equity issued before the relevant sanctions effective date by entities subject to it?

989 … No, so long as the terms of such debt (including the repayment period, the interest rate, and the amount) were contractually agreed to before the relevant sanctions effective date described in the Russia-related Entities Directive and are not modified on or after the relevant sanctions… Read more

990. May a debit to an account of a person blocked pursuant to Executive Order (E.O.) 14024 be authorized as a transaction that is ordinarily incident and necessary to a licensed transaction?

990 … An authorization for transactions that are ordinarily incident and necessary to a transaction licensed pursuant to E.O. 14024 does not implicitly authorize a debit to a blocked account on the books of a U.S. financial institution. Debits to an account on the books of a U.S. financial… Read more

991. Why did the Department of the Treasury issue Afghanistan-related General License (GL) 20, “Authorizing Transactions Involving Afghanistan or Governing Institutions in Afghanistan”?

991 … The U.S. government recognizes that Afghanistan is facing a widespread humanitarian and economic crisis. Treasury issued Afghanistan-related GL 20 to ensure that U.S. sanctions do not stand in the way of transactions and activities that support basic human needs of the people in Afghanistan… Read more

992. What are examples of activities authorized by Afghanistan-related General License (GL) 20, “Authorizing Transactions Involving Afghanistan or Governing Institutions in Afghanistan”?

992 … Transactions that are generally authorized by GL 20 to the extent authorization is required include: Commercial transactions involving Afghanistan, including imports from Afghanistan, exports to Afghanistan, and commercial transactions within or involving the geographical territory of… Read more

993. What if a governing institution in Afghanistan is led by an individual who appears on the Office of Foreign Assets Control’s List of Specially Designated Nationals and Blocked Persons?

993 … Generally speaking, when a designated individual has a leadership role in a governing institution, the governing institution itself is not considered blocked. Accordingly, engaging in a routine interaction with an agency in which a blocked individual is an official, but that does not involve… Read more

994. For purposes of Afghanistan-related General License (GL) 20, “Authorizing Transactions Involving Afghanistan or Governing Institutions in Afghanistan,” what are luxury items and services?

994 … For purposes of GL 20 , luxury items and services are those items and services that are not linked to activities that support basic human needs as defined with reference to United Nations Security Council Resolution 2615 (2021), for instance: yachts, furs, designer clothing, and certain… Read more

995. Does Afghanistan-related General License (GL) 20 authorize financial transfers to governing institutions in Afghanistan, including the Central Bank of Afghanistan (Da Afghanistan Bank, or DAB), or state-owned or -controlled companies and enterprises in Afghanistan? Does Afghanistan-related GL 20 authorize receipt of payment from governing institutions in Afghanistan and state-owned or -controlled companies and enterprises in Afghanistan?

995 … Yes. To the extent authorization is required, GL 20 authorizes financial transfers to or involving all governing institutions in Afghanistan — including but not limited to the DAB, Ministry of Education, Ministry of Energy and Water, Ministry of Finance, Ministry of Agriculture, Irrigation… Read more

996. In light of the issuance of Afghanistan-related General License (GL) 20, are U.S. persons still required to abide by the narrower scope of Afghanistan-related GLs 14, 15, 16, 17, 18, and 19?

996 … To the extent authorization is required, Afghanistan-related GL 20 authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR) , the Foreign Terrorist Organizations Sanctions… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence