Frequently Asked Questions

315. Will routine payments or fees be subject to sanctions if they are made to a person determined to be a port operator in Iran and if the vessel is carrying non-sanctioned goods?

315 … Any company involved in loading or unloading cargo in Iran should exercise great caution to avoid engaging in transactions with entities designated by the United States, including the Tidewater Middle East Co. which was designated for its involvement in Iran’s proliferation of weapons of mass… Read more

298. For purposes of IFCA, what materials are considered graphite, raw or semi-finished metals?

298 … For purposes of IFCA , we anticipate that regulations to be promulgated will define graphite, raw or semi-finished metals described in section 1245(d) of IFCA to include steels; aluminum metal and its alloys; base metals of single or complex borides of titanium; beryllium metal and its alloys… Read more

961. Can nongovernmental organizations (NGOs) and international organizations (IOs) provide support to municipal water systems?

961 … Yes. Support to municipal water systems by NGOs for projects that directly benefit the Afghan people or otherwise relieve human suffering that would otherwise be prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions… Read more

962. Can banks process transactions related to activities authorized by General Licenses (GLs) 14, 15, 16, 17, 18, 19, and 20?

962 … Yes. Transactions that are ordinarily incident and necessary to give effect to the activities authorized in General Licenses (GL) 14 , GL 15 , GL 16 , GL 17 , GL 18 , GL 19 , or GL 20 , including clearing, settlement, and transfers through, to, or otherwise involving privately owned and… Read more

963. Can humanitarian organizations ship cash into Afghanistan for use in delivering humanitarian assistance?

963 … Yes, cash shipments to Afghanistan may be authorized under General Licenses (GL) 14 , GL 18 , GL 19 , or GL 20 provided that they are ordinarily incident and necessary to effectuate the activities authorized by the GLs. As with all OFAC GLs, GLs 14, 18, 19, and 20 are “self-executing,”… Read more

972. Do non-U.S. financial institutions have to comply with the prohibitions of Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?

972 … Under the Russia-related CAPTA Directive , U.S. financial institutions are prohibited from the opening or maintaining of a correspondent account or payable-through account for or on behalf of, or from processing of a transaction involving, a foreign financial institution determined to be… Read more

984. What does Directive 3 under Executive Order (E.O.) 14024, "Prohibitions Related to New Debt and Equity of Certain Russia-related Entities" (Russia-related Entities Directive) prohibit?

984 … The Russia-related Entities Directive prohibits certain dealings by U.S. persons or within the United States in new debt of longer than 14 days maturity or new equity of Russian entities determined to be subject to the prohibitions of the directive or their property or interests in property.… Read more

966. What actions did Treasury take in February 2022 related to Russia's financial services sector pursuant to Executive Order (E.O.) 14024?

966 … Treasury took expansive sanctions actions related to Russia's financial services sector in February 2022 as detailed below. Financial services sector determination . On February 22, 2022, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination… Read more

967. What does Directive 2 under Executive Order (E.O.) 14024, "Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions" (Russia-related CAPTA Directive) prohibit?

967 … The Russia-related CAPTA Directive prohibits U.S. financial institutions from: (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA… Read more

968. What foreign financial institutions are listed in Annex 1 to Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?

968 … Annex 1 to the Russia-related CAPTA Directive identifies Public Joint Stock Company Sberbank of Russia as well as many of its foreign financial institution subsidiaries. The foreign financial institutions listed in Annex 1 have been determined to be subject to the prohibitions of the Russia-… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence