Frequently Asked Questions

1118. As of December 2022, the Government of the Russian Federation may require a so-called "exit tax" payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called "exit tax"? Does Russia-related General License (GL) 13O authorize transactions that involve the payment of this exit tax?

1118 … Directive 4 under Executive Order (E.O.) 14024, "Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation," as amended (Russia-related Sovereign… Read more

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

736. May the U.S. dollar be used to conduct transactions in Cuba or with Cuban nationals?

736 … Yes, under certain circumstances. Persons subject to U.S. jurisdiction may engage in transactions in U.S. dollars in Cuba or with Cuban nationals with respect to activity that is authorized pursuant to the Cuban Assets Control Regulations (CACR) . For example, payments for telecommunications… Read more

1136. Can U.S. persons purchase bonds issued by the Government of Venezuela or Petróleos de Venezuela, S.A. (PdVSA) prior to August 25, 2017 on the secondary market?

1136 … Yes. On October 18, 2023, OFAC issued amended General Licenses (GLs) 3I and 9H , to remove the restriction that any divestment by U.S. persons of holdings in GL 3I Bonds (as defined in GL 3I and FAQ 662 ) or PdVSA Securities (as defined in GL 9H and FAQ 661 ) must be to non-U.S. persons. GL… Read more

1137. For purposes of General License (GL) 45B, “Authorizing Certain Repatriation Transactions Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A.,” what countries are included in the “Western Hemisphere”?

1137 … For the purposes of GL 45B, OFAC considers the term “Western Hemisphere” to mean those countries and areas identified by the Department of State on its website as comprising the Western Hemisphere. Please see: Bureau of Western Hemisphere Affairs - United States Department of State. Date… 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?

1138 … 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 rexportation, directly or indirectly, of financial services to or for the benefit of Myanma Oil and Gas Enterprise (MOGE… Read more

1139. Does the 50 Percent Rule apply to 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)?

1139 … Yes. The prohibitions in the MOGE Financial Services Directive apply to MOGE “or its property or interests in property,” including any entity, such as a subsidiary or joint venture, that is 50 percent or more owned, directly or indirectly, by MOGE, except to the extent otherwise provided by… Read more

1140. In light of the designation of Orka Holding, are U.S. persons authorized to engage in transactions related to the provision of medicine, medical devices, and medical services involving Orka Holding and its subsidiaries?

1140 … Yes. As a general matter, humanitarian trade is not the target of U.S. sanctions. Concurrent with the designation of Orka Holding AD, OFAC issued Western Balkans General License (GL) 3 , which authorizes all transactions involving Orka Holding AD related to: (1) the production,… Read more

1141. Does Venezuela General License (GL) 45B authorize U.S. persons to provide certain services, including refueling services, repair, and maintenance, to blocked Conviasa aircraft that are carrying out flights for the exclusive purpose of repatriating Venezuelan nationals from a third country in the Western Hemisphere to Venezuela?

1141 … Yes. Date updated: March 01, 2024 … Does Venezuela General License (GL) 45B authorize U.S. persons to provide certain services, including refueling services, repair, and maintenance, to blocked Conviasa aircraft that are carrying out flights for the exclusive purpose of repatriating… Read more

1145. What if a governing institution in Afghanistan is led by an individual who has been blocked pursuant to the Global Magnitsky Sanctions Regulations?

1145 … Generally, the designation of an individual with a leadership role in a governing institution does not itself block the governing institution. Accordingly, engaging in a routine interaction with a governing institution in which a blocked individual is an official, but that does not directly… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence