Frequently Asked Questions

849. Can a foreign financial institution (FFI) be excluded or removed from the Section 5(b) Report so that sanctions under the Hong Kong Autonomy Act (HKAA) would not apply?

849 … Pursuant to section 5(d)(2) of the HKAA , an FFI may be excluded from the Section 5(b) Report or an update to that report under section 5(e) of the HKAA, or may be removed from the Section 5(b) Report or an update to that report prior to the imposition of sanctions under section 7(a), if the… Read more

850. How does the Treasury Department determine whether a transaction is “significant” for purposes of section 5(b) of the Hong Kong Autonomy Act (HKAA)?

850 … For purposes of implementing section 5(b) of the HKAA , the Secretary of the Treasury may consider the totality of the facts and circumstances when determining whether transactions are “significant.” As a general matter, the Treasury Department may consider some or all of the following… Read more

851. How will the following key terms in section 5(b) of the Hong Kong Autonomy Act (HKAA) be defined: “financial institution” and “knowingly”?

851 … Section 2 of HKAA defines these terms as follows, which OFAC intends to incorporate into relevant regulations: “financial institution” – the term “financial institution” is defined to have the same meaning as a financial institution specified in section 5312(a)(2) of title 31, United States… Read more

852. What did the October 27, 2020 amendment to the Cuban Assets Control Regulations (CACR) do?

852 … On October 27, 2020, OFAC issued an amendment to the CACR, effective November 26, 2020, to remove from the scope of certain remittance-related general authorizations any transactions involving entities or subentities identified on the State Department’s Cuba Restricted List . Specifically,… Read more

853. Can U.S. academic institutions provide online learning services to Iranian students located outside the United States? Can U.S. technology companies provide software and services to assist Iranian students in accessing online coursework?

853 … General licenses issued under the Iranian Transactions and Sanctions Regulations (ITSR) authorize certain U.S. academic institutions and other U.S. persons to provide certain services and software to Iranian students. These general licenses include: General License G (GL G) authorizes… Read more

916. What does Executive Order (E.O.) of August 9, 2021, “Blocking Property of Additional Persons Contributing to the Situation in Belarus,” do?

916 … E.O. of August 9, 2021 expands the scope of the national emergency pertaining to Belarus declared in E.O. 13405, “Blocking Property of Certain Persons Undermining Democratic Processes or Institutions in Belarus ,” to provide additional authorities under which sanctions may be imposed against… Read more

917. Are all persons operating in sectors identified in the Executive Order (E.O.) of August 9, 2021, “Blocking Property of Additional Persons Contributing to the Situation in Belarus,” blocked?

917 … No. E.O. of August 9, 2021 authorizes the imposition of blocking sanctions on persons operating in certain identified sectors of the Belarus economy, including the defense and related materiel sector, security sector, energy sector, potassium chloride (potash) sector, tobacco products… Read more

918. What does Belarus General License 4 (GL 4), “Authorizing the Wind Down of Transactions Involving Belaruskali OAO,” authorize?

918 … GL 4 authorizes, through 12:01 a.m. eastern standard time, December 8, 2021, all transactions and activities prohibited by Executive Order (E.O.) 14038 that are ordinarily incident and necessary to the wind down of transactions involving Belaruskali OAO, or any entity in which Belaruskali… Read more

919. How do sanctions related to U.S. bank loans imposed on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Act of 1991 (CBW Act), as announced by the State Department on August 20, 2021, affect existing prohibitions?

919 … The prohibitions announced by the State Department on August 20, 2021 related to U.S. bank loans have the same scope as those imposed by OFAC in August 2019 under the CBW Act Directive . Please see FAQs 675 – 678 for additional information. Independent of the CBW Act Directive, OFAC has… Read more

920. How are the sanctions related to import restrictions imposed on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Act of 1991 (CBW Act), as announced by the State Department on August 20, 2021, being implemented?

920 … The announced import restrictions related to the permanent importation of firearms and ammunition that are the growth, product, or manufacture of the Russian Federation will be implemented by the U.S. Department of Justice, Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). OFAC has… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence