Frequently Asked Questions

903. Do the prohibitions of Executive Order (E.O.) 13959, as amended, apply to U.S. persons who are employed by non-U.S. entities and who, in the ordinary course of their employment, are involved in purchases or sales of Chinese Military-Industrial Complex Companies’ (CMICs) securities on behalf of their non-U.S. employer?

903 … For purposes of E.O. 13959, as amended, U.S. persons employed by non-U.S. entities are not prohibited from being involved in, or otherwise facilitating, purchases or sales related to a covered security on behalf of their non-U.S. employer, provided that such activity is in the ordinary course… Read more

904. Under Executive Order (E.O.) 13959, as amended, are U.S. market makers permitted to facilitate divestment from publicly traded securities of Chinese Military-Industrial Complex Companies (CMICs)?

904 … Yes. U.S. market makers, and non-U.S. market makers who employ U.S. persons, are permitted to engage in activities that are necessary to effect divestiture during the during the 365-day periods in which divestment transactions are permitted or that are not otherwise prohibited under E.O.… Read more

905. Does Executive Order (E.O.) 13959, as amended, prohibit U.S. persons from engaging in all activities with companies listed on the Non-SDN Chinese Military-Industrial Complex Companies List (the "NS-CMIC List")?

905 … No. The prohibitions of E.O. 13959, as amended, apply only with respect to certain purchases or sales of publicly traded securities of entities listed on the NS-CMIC List. E.O. 13959, as amended, does not prohibit activity with entities listed on the NS-CMIC List that is unrelated to such… Read more

556. When are the prohibitions and strict conditions on foreign financial institutions’ correspondent accounts or payable-through accounts in the United States pursuant to Executive Order (E.O.) 13810 effective?

556 … Pursuant to E.O. 13810 and the North Korea Sanctions Regulations, a finding by the Treasury Department that a foreign financial institution knowingly engages in one or more of the sanctionable activities is necessary before the Treasury Department can prohibit or impose strict conditions on… Read more

557. How will U.S. and foreign financial institutions (FFIs) know that the Treasury Department has imposed prohibitions or strict conditions on FFIs’ correspondent accounts or payable-through accounts in the United States pursuant to § 510.210 of the North Korea Sanctions Regulations (NKSR)?

557 … If, pursuant to the NKSR, Treasury decides to impose strict conditions on maintaining U.S. correspondent accounts or U.S. payable-through accounts for an FFI, or decides to prohibit the opening or maintaining of U.S. correspondent accounts or U.S. payable-through accounts for an FFI, Treasury… Read more

558. Are news reporting organizations and journalists authorized to conduct activities in North Korea?

558 … The general license at § 510.522 of the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR), authorizes news reporting organizations that are U.S. persons, and their U.S. person employees to engage in certain transactions in North Korea, provided that such transactions are ordinarily… Read more

104. Can an insurer offer global travel insurance and worldwide travel assistance without violating U.S. sanctions?

104 … Yes, provided that the provision of global travel insurance and travel assistance relate to travel that is exempt or authorized. The authority granted to the President by the International Emergency Economic Powers Act (IEEPA) does not include the authority to regulate or prohibit, directly… Read more

452. Are these sanctions consistent with international obligations?

452 … As with all financial sanctions programs Treasury administers, these measures will be implemented in accordance with domestic law and our international obligations. … Are these sanctions consistent with international …

659. Does Venezuela-related General License 12 authorize U.S. persons to export goods, services, and technology from the United States to Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest during the wind-down period?

659 … General License 12 authorizes, until 12:01 a.m. eastern standard time, February 27, 2019, all transactions and activities that are ordinarily incident and necessary to the wind down of operations, contracts, or other agreements that were in effect prior to January 28, 2019. This… Read more

660. When will sanctions be lifted on Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest?

660 … The path to sanctions relief for PdVSA and its subsidiaries is through the expeditious transfer of control of the company to a democratically elected government that is committed to taking concrete and meaningful actions to combat corruption, restore democracy, and respect human rights. A… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence