Frequently Asked Questions

1198. In light of the designation of Shreya Life Sciences Private Limited (Shreya), are U.S. persons authorized to engage in transactions related to pharmaceutical and other humanitarian-related goods involving Shreya and its subsidiaries?

1198 … Yes. As a general matter, humanitarian trade is not the target of U.S. sanctions. OFAC has issued Russia-related General License (GL) 6D , which authorizes, among other things, certain transactions related to the production, manufacturing, sale, transport, or provision of medicine and… Read more

1199. Can a claim be paid under a policy issued to a blocked individual or entity if the payment is to an innocent third-party (for example, the injured party in an automobile accident)?

1199 … The insurance company should contact OFAC for additional guidance. OFAC will work with you on the specifics of the case. Although authorizing payments to blocked persons is rarely aligned with the U.S. foreign policy and national security objectives of OFAC sanctions, circumstances may weigh… Read more

1200. If a non-sanctioned person files a claim with their insurance company for a loss caused by a blocked person, such as a designated terrorist organization, is the insurance company permitted to pay the claim?

1200 … OFAC is aware that insurers at times receive claims from non-sanctioned persons in non-comprehensively sanctioned jurisdictions for losses caused by individuals or entities on OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List). For example, a U.S. insurance company… Read more

837. What did the September 24, 2020 amendment to the Cuban Assets Control Regulations (CACR) do?

837 … Effective September 24, 2020, OFAC issued an amendment to the CACR restricting imports of Cuban-origin alcohol and tobacco products, as well as specific categories of authorized travel to Cuba related to professional meetings or conferences and certain public performances or other events, and… Read more

838. What is the Cuba Prohibited Accommodations List and how do I know if I am authorized to lodge or pay for lodging at a property in Cuba?

838 … No person subject to U.S. jurisdiction may lodge, pay for lodging, or make any reservation for or on behalf of a third party to lodge, at any property that the Secretary of State has identified as a property in Cuba that is owned or controlled by: the Cuban government; a prohibited official… Read more

839. Are authorized travelers who have initiated travel arrangements prior to the addition of a property on the State Department’s Cuba Prohibited Accommodations List required to cancel their Cuba-related travel plans if their travel arrangements involve lodging at a listed property?

839 … Consistent with the Administration’s interest in avoiding negative impacts on Americans for arranging lawful travel to Cuba, any existing travel-related arrangements that include lodging at properties in Cuba identified on the Cuba Prohibited Accommodations List will continue to be permitted… Read more

840. If an official of the Government of the Hong Kong Special Administrative Region (HKSAR) is designated as a Specially Designated National (SDN), does that mean that the HKSAR government is blocked? What are the prohibitions on U.S. persons dealing with a designated HKSAR government official?

840 … The designation of an official of the Government of the HKSAR does not itself block the HKSAR government or any government agency where the SDN is an official or otherwise exercises control. Accordingly, engaging in a routine interaction with an agency in which an SDN is an official, but… Read more

842. What does General License L (GL L) authorize with respect to the financial sector of Iran and Iranian financial institutions (Iranian FIs) now sanctioned pursuant to Executive Order (E.O.) 13902?

842 … GL L authorizes under E.O. 13902 all transactions and activities involving Iranian FIs blocked pursuant to E.O. 13902 that are authorized, exempt, or otherwise not prohibited under the Iranian Transactions and Sanctions Regulations (ITSR). E.O. 13902, which was issued on January 10, 2020, is… Read more

843. I’m a U.S. person that relied on general or specific licenses issued pursuant to the Iranian Transactions and Sanctions Regulations (ITSR) to conduct humanitarian-related or other transactions and activities prior to the identification of the financial sector of Iran and sanctioning of a number of Iranian financial institutions (Iranian FIs) under E.O. 13902. Is any further authorization needed to conduct such transactions following these actions?

843 … No. General License (GL) L extends authorizations provided through specific and general licenses issued under the ITSR to apply to transactions and activities involving Iranian FIs blocked pursuant to E.O. 13902 . Further authorization from OFAC beyond GL L is not required under E.O. 13902… Read more

844. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions, or other activities that would be authorized under the Iranian Transactions and Sanctions Regulations and General License (GL) L if engaged in by a U.S. person, involving Iranian financial institutions (Iranian FIs) sanctioned pursuant to E.O. 13902?

844 … No. Non-U.S. persons generally do not risk exposure to U.S. secondary sanctions for engaging in the sale of agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in E.O. 13902 and other applicable sanctions authorities… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence