Frequently Asked Questions

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

1146. What does Executive Order (E.O.) 14114, “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities,” do?

1146 … E.O. 14114 amends E.O. 14024 and E.O. 14068 to further address the Russian Federation’s continued use of its military-industrial base to aid its effort to undermine security in countries and regions important to United States national security and to further counteract the Russian Federation… Read more

1147. How does Executive Order (E.O.) 14114 amend E.O. 14024, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation”?

1147 … E.O. 14114 amends E.O. 14024 to authorize the imposition of sanctions on foreign financial institutions (FFIs) that have engaged in certain transactions involving Russia’s military-industrial base, including all persons whose property and interests in property are blocked pursuant to E.O.… Read more

1148. What activities could expose a foreign financial institution (FFI) to sanctions under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?

1148 … FFIs may be sanctioned for engaging in certain transactions, or providing any service, involving Russia’s military-industrial base. For example, FFIs may be sanctioned for conducting any significant transaction(s) for any person that has been blocked pursuant to E.O. 14024. FFIs may also… Read more

1149. What sanctions can be imposed on a foreign financial institution (FFI) that engaged in conduct described in section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114? What are the obligations of U.S. financial institutions?

1149 … Pursuant to subsection 11(b) of E.O. 14024 , as amended, OFAC may block FFIs or prohibit the opening or prohibit or impose strict conditions on the maintenance of correspondent accounts or payable-through accounts in the United States for such FFIs. For FFIs for which the opening or… Read more

1150. What does determination of December 22, 2023, “Determination Pursuant to Section 11(a)(ii) of Executive Order (E.O. 14024)” (Russia Critical Items Determination) do?

1150 … The Russia Critical Items Determination issued pursuant to subsection 11(a)(ii) of E.O. 14024 identifies certain items that support Russia’s military-industrial base. Foreign financial institutions (FFIs) may be sanctioned for having conducted or facilitated any significant transaction or… Read more

1203. What does General License (GL) 115A ("Authorizing Certain Transactions Related to Civil Nuclear Energy") authorize with respect to civil nuclear energy-related payments?

1203 … GL 115A generally authorizes certain transactions related to civil nuclear energy involving certain entities that are sanctioned pursuant to Executive Order 14024. Civil nuclear energy means the following activities when undertaken solely to maintain or support civil nuclear energy projects… Read more

1204. On December 27, 2024, OFAC designated Bidzina Ivanishvili (Ivanishvili) pursuant to Executive Order (E.O.) 14024. Can I continue to engage in transactions or other dealings with entities owned by Ivanishvili that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

1204 … Yes. Although transactions or other dealings involving Ivanishvili are generally prohibited as a result of OFAC's designation, OFAC concurrently issued General License (GL) 116 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ivanishvili provided… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence