Frequently Asked Questions

259. What can a foreign financial institution (FFI) do with the funds resulting from the import of Iranian-origin goods or services once the funds are credited to an account? Can funds be transferred to other accounts?

259 … Section 504 of the TRA requires that, in order for a sanctionable transaction to fall within the bounds of the significant reduction exception , any funds owed to Iran as a result of the bilateral trade transaction must be credited to an "account located in the country with primary… Read more

370. What do the prohibitions in Directives 1 and 2 mean? Are they blocking actions?

370 … The sectoral sanctions imposed on specified persons operating in sectors of the Russian economy identified by the Secretary of the Treasury were done under Executive Order 13662 through Directives issued by OFAC pursuant to its delegated authorities. Directive 1, as amended on September 29,… Read more

984. What does 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?

984 … The Russia-related Entities Directive prohibits certain dealings by U.S. persons or within the United States in new debt of longer than 14 days maturity or new equity of Russian entities determined to be subject to the prohibitions of the directive or their property or interests in property.… Read more

931. Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions that U.S. persons would be authorized to engage in under Afghanistan-related General Licenses (GLs) 14, 15, 16, or 20?

931 … No. Non-U.S. persons may engage in or facilitate transactions that would be authorized for U.S. persons under Afghanistan-related GLs 14 , 15 , 16 , 17 , 18 , 19 , or 20 without exposure to sanctions under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign… Read more

978. For transactions authorized under Russia-related General Licenses (GL) 6D, 7A, or GL 115B what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024?

978 … GLs 6D , 7A , or 115B do not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of entities subject to the prohibitions of Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through… Read more

1017. Does Russia-related General License (GL) 8L remain valid following the issuance of Executive Order (E.O.) 14066, "Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine"?

1017 … Yes. GL 8L , which authorizes the wind-down of energy related transactions involving specified Russian financial institutions, remains in effect until 12:01 a.m. eastern daylight time, March 12, 2025, unless renewed. However, GL 8L does not authorize any transactions prohibited by E.O. 14066… Read more

1160. What changes did the February 15, 2024 regulatory amendment to the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR), make?

1160 … On February 15, 2024, OFAC, in consultation with the Department of State, amended the NKSR to modify an existing general license (GL) and add three new GLs to facilitate humanitarian-related and other activities in North Korea. These changes include: Additional non-governmental organization… Read more

1161. Does the general license for non-governmental organization (NGO) activities at section 510.512 of the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR), authorize NGOs to engage in transactions involving the Government of North Korea?

1161 … Yes, subject to certain conditions and limitations. NGOs may engage in transactions with the Government of North Korea to the extent ordinarily incident and necessary to the activities authorized by § 510.512(a). Such transactions may not include partnerships and partnership agreements… Read more

1162. What must a non-governmental organization (NGO) do before relying on the general license (GL) at § 510.512 of the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR)?

1162 … To be eligible for the NGO GL, an NGO must first submit a report to the U.S. Department of State via email to DPRK-NGO-GL-Notification-DL@state.gov no fewer than 30 days before the commencement of their activities, with one of the following: (1) a copy of approval by the UN Security Council… Read more

1163. Can I export tobacco or other luxury goods to North Korea?

1163 … No. The general license for the exportation or reexportation of certain agricultural and medical items at § 510.521 of the North Korea Sanctions Regulations, 31 CFR part 510, does not authorize the exportation or reexportation to North Korea of luxury goods, including tobacco, as set forth… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence