Frequently Asked Questions

1197. I'm a U.S. person with securities held at the National Settlement Depository (NSD), which were transferred pursuant to Russian Decree 840 to another Russian registrar. Am I required to block these securities?

Yes. On June 12, 2024, OFAC designated the National Settlement Depository (NSD), along with the Moscow Exchange (MOEX) and the National Clearing Center (NCC) pursuant to Executive Order (E.O.) 14024 for operating or having operated in the financial services sector of the Russian Federation economy… Read more

336. How do I know whether a person is identified under E.O. 13608?

On December 18, 2025, the remaining name on the FSE list was removed. As a result, the FSE list is currently empty. However, new names may be added to this list at any time in the future. Please refer to the Foreign Sanctions Evaders (FSE) List …

401. OFAC’s 50 Percent Rule states that the property and interests in property of entities directly or indirectly owned 50 percent or more in the aggregate by one or more blocked persons are considered blocked. How does OFAC interpret indirect ownership as it relates to certain complex ownership structures?

"Indirectly," as used in OFAC’s 50 Percent Rule , refers to one or more blocked persons' ownership of shares of an entity through another entity or entities that are 50 percent or more owned in the aggregate by the blocked person(s). OFAC urges persons considering a potential transaction to conduct… Read more

1059. Do the determinations made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” on September 15, 2022, “Prohibitions Related to Certain Quantum Computing Services,” and on May 19, 2023, “Prohibitions Related to Architecture and Engineering Services” (“the determinations”), prohibit U.S. persons from providing services to persons located outside of the Russian Federation that are owned or controlled by persons located in the Russian Federation?

No, provided that the provision of services is not an indirect export to a person located in the Russian Federation. For the purposes of these determinations, OFAC interprets the “indirect” provision of the prohibited services to include when the benefit of the services is ultimately received by a… Read more

1058. For the purposes of section 1(a)(ii) of Executive Order (E.O.) 14071, what is meant by the term “person located in the Russian Federation”?

For the purposes of section 1(a)(ii) of E.O. 14071 , OFAC interprets “person located in the Russian Federation” to include persons in the Russian Federation, individuals ordinarily resident in the Russian Federation, and entities incorporated or organized under the laws of the Russian Federation or… Read more

1138. What does Directive 1 under Executive Order 14014, "Prohibitions Related to Financial Services to or for the Benefit of Myanma Oil and Gas Enterprise" (MOGE Financial Services Directive) prohibit?

Pursuant to the MOGE Financial Services Directive , the following activities by a U.S. person are prohibited on or after December 15, 2023: the provision, exportation, or reexportation, directly or indirectly, of financial services to or for the benefit of Myanma Oil and Gas Enterprise (MOGE).… Read more

367. What is the definition of a “bioactive peptide”?

For purposes of the relevant exclusion from the agricultural commodities general license in the Iranian Transactions and Sanctions Regulations( ITSR ), the term “bioactive peptide” means an item that must be less than 50 amino acids in length and bioactive (antioxidant, antiallergic, antimicrobial… Read more

207. What were the criteria for Treasury's CISADA finding against Bank of Kunlun? How many other institutions were you looking at and why did you decide to take action against Bank of Kunlun?

Based on information made available to the Treasury Department, the Department has found that China's Bank of Kunlun has knowingly facilitated significant transactions for various Iranian-linked banks designated by the United States under our WMD or terrorism authorities. Upon finding that Bank of… Read more

1230. Can an entity that is not an "established U.S. entity" be involved in transactions authorized by Venezuela General License (GL) 46?

Yes. Non-U.S. persons may engage in transactions or provide services that are ordinarily incident and necessary to the established U.S. entity’s transactions authorized by GL 46. Such activities or ancillary services could include: providing transportation and logistics services to an established U… Read more

1233. Are all entities engaged in a transaction authorized by Venezuela General License (GL) 46 required to have contracts with the dispute resolution requirement included in paragraph (a)(1)?

No. The dispute resolution requirement in paragraph (a)(1) of GL 46 applies only to contracts governing transactions undertaken by an established U.S. entity when the contract is with the Government of Venezuela (GOV), Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns,… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence