Frequently Asked Questions

869. If a person is subject to non-blocking menu-based sanctions described in section 235(a) of the Countering America’s Adversaries Through Sanctions Act (CAATSA), do the same non-blocking sanctions apply to entities owned 50 percent or more by the listed person?

869 … No. If a person is listed on OFAC’s Non-SDN Menu-Based Sanctions List (NS-MBS List) as subject to only a combination of the sanctions described in section 235(a)(1-8) and (10-11) of CAATSA , as implemented by Executive Order (E.O.) 13849 , these non-blocking sanctions do not apply to an… Read more

870. On December 14, 2020, OFAC added a person to the Non-SDN Menu-Based Sanctions List (NS-MBS List) and indicated that the person was subject to the loan and credit-related sanction described in section 235(a)(3) of the Countering America’s Adversaries Through Sanctions Act (CAATSA). What does this sanction prohibit?

870 … With respect to a person on the NS-MBS List subject to section 235(a)(3) of CAATSA , as implemented by section 1(a)(i) of Executive Order (E.O.) 13849 , U.S. financial institutions are prohibited from making loans or providing credits to the identified person totaling more than $10,000,000 in… Read more

865. May market intermediaries and other participants facilitate divestment from publicly traded securities of Chinese Military-Industrial Complex Companies (CMICs), including divestment by investment fund managers?

865 … Yes. Market intermediaries, including market makers, and other participants may engage in ancillary or intermediary activities that are necessary to effect divestiture during the relevant wind-down periods or that are not otherwise prohibited under E.O. 13959, as amended. Purchases or sales… Read more

871. What are the compliance obligations of securities exchanges operated by U.S. persons with respect to Executive Order (E.O.) 13959, as amended?

871 … Consistent with FAQ 865 , which clarifies that market intermediaries and other participants may engage in ancillary or intermediary activities that are necessary to effect divestiture during the relevant wind-down periods or that are not otherwise prohibited under E.O. 13959, as amended,… Read more

1201. What authorizations exist for diplomatic or consular missions operating in or outside of Russia and Russian diplomatic or consular missions operating abroad?

1201 … The Office of Foreign Assets Control (OFAC) has issued several authorizations related to U.S. and third-country diplomatic or consular missions operating in or outside of Russia and Russian diplomatic or consular missions operating abroad. Russian Diplomatic or Consular Missions, Wherever… Read more

1202. Following the November 21, 2024 designation of Russian financial institutions, Treasury has now designated a significant number of financial institutions in Russia. Will this negatively impact the processing of personal, non-commercial remittances to or from Russia?

1202 … No. Treasury's sanctions target Russian financial institutions that have continued to help Russia gain access to the critical goods it needs to prosecute its war in Ukraine. As a general matter, personal, non-commercial remittances are not the target of sanctions imposed by the United States… Read more

1204. On December 27, 2024, OFAC designated Bidzina Ivanishvili (Ivanishvili) pursuant to Executive Order (E.O.) 14024. Can I continue to engage in transactions or other dealings with entities owned by Ivanishvili that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

1204 … Yes. Although transactions or other dealings involving Ivanishvili are generally prohibited as a result of OFAC's designation, OFAC concurrently issued General License (GL) 116 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ivanishvili provided… Read more

1213. For the purposes of the determination of January 10, 2025 made pursuant to Executive Order (E.O.) 14024 (the "January 2025 Energy Sector Determination"), what is meant by the term "energy sector of the Russian Federation economy"?

1213 … On January 10, 2025, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the energy sector of the Russian… Read more

1214. Does the determination of January 10, 2025, made pursuant to Executive Order (E.O.) 14024 (the "January 2025 Energy Sector Determination") mean that all persons that operate or have operated in this sector of the Russian Federation economy are sanctioned by OFAC?

1214 … No. On January 10, 2025, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the energy sector of the Russian… Read more

1009. Does Executive Order (E.O.) 14065 block the entire Donetsk and Luhansk oblasts?

1009 … No. E.O. 14065 targets the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”). In… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence