OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries ("LIG Entities"): GL 128C and GL 131E . The GLs are similar but have different expiration dates and terms as each serves a different purpose. To mitigate the… Read more
On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia's energy sector and degrade Russia's ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-… Read more
Yes. Executive Order (E.O.) 13599 , as implemented by section 560.211(b) of the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), blocks the property and interests in property of Iranian financial institutions. An Iranian financial institution is blocked pursuant to E.O. 13599… Read more
The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity… Read more
On May 7, 2026, OFAC issued Cuba-related GL 1 , authorizing all transactions prohibited by E.O. 14404 where such transactions are authorized or exempt under the Cuban Assets Control Regulations, 31 CFR part 515 ( CACR ). GL 1 includes transactions authorized by either general or specific license… Read more
Generally, yes, but the U.S. government does not intend to target foreign persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the wind down of transactions involving GAESA, or any entity in which GAESA owns, directly or indirectly, a 50… Read more
No. Persons blocked or otherwise identified pursuant to the CACR are not automatically blocked pursuant to the E.O. 14404 . The CACR and E.O. 14404 are separate sanctions authorities. E.O. 14404 separately authorizes the imposition of blocking sanctions and certain less-than-blocking sanctions… Read more
No. E.O. 14404 authorizes the Secretary of the Treasury, in consultation with the Secretary of State, or the Secretary of State, in consultation with the Secretary of the Treasury, to impose blocking sanctions on any foreign person determined to operate or have operated in the following sectors of… Read more
No. All existing prohibitions and authorizations pursuant to the CACR remain in effect. E.O. 14404 was issued pursuant to the International Emergency Economic Powers Act ( IEEPA ), and is distinct from the CACR, which is issued pursuant to the Trading with the Enemy Act ( TWEA ), among other… Read more
E.O. 14404 takes additional steps with respect to the national emergency declared in E.O. 14380 of January 29, 2026, "Addressing Threats to the United States by the Government of Cuba." E.O. 14404 authorizes the imposition of sanctions by the Secretary of the Treasury and the Secretary of State on… Read more