Frequently Asked Questions

887. Are persons identified pursuant to Executive Order (E.O.) 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy blocked pursuant to E.O. 14024?

887 … Persons identified pursuant to E.O. 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy are not subject to prohibitions under E.O. 14024 unless those persons are also sanctioned pursuant to E.O. 14024. For more… Read more

889. Does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) prohibit participation in the secondary market for bonds issued by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation?

889 … Yes (see FAQ 888 and FAQ 965 ). Date Updated: February 22, 2022 … Does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) prohibit participation in the secondary market for bonds… Read more

890. Prior to June 14, 2021, are U.S. financial institutions prohibited from participating in the primary market for ruble or non-ruble denominated bonds issued by, or lending ruble or non-ruble denominated funds to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation?

890 … Even prior to June 14, 2021, “U.S. banks” were prohibited from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign (including the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of… Read more

891. Does the 50 Percent Rule apply to Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive)?

891 … No. The prohibitions of the Russia-related Sovereign Debt Directive apply only to bonds issued by, or loans made to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation. The prohibitions of the… Read more

593. If a blocked person holds an equity interest in a foreign entity, and the foreign entity is not itself a blocked person pursuant to OFAC’s fifty percent rule, can the foreign entity be sanctioned under section 10 of SSIDES, as amended by section 228 of CAATSA, and section 5 of UFSA, as amended by section 226 of CAATSA, for paying dividends to the blocked person?

593 … Whether paying dividends to a blocked person who holds an equity interest in the foreign company of less than fifty percent, individually or in the aggregate, would result in OFAC imposing sanctions under these authorities on the payer of the dividends depends on whether OFAC determines that… Read more

541. What activities can trigger sanctions on a foreign financial institution (FFI) under section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated into § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR)?

541 … Section 226 of CAATSA amended section 5 of UFSA to make the sanctions in that section, which were previously discretionary, mandatory. This section is implemented in § 589.209 of the URSR. Under § 589.209, FFIs face sanctions if the Secretary of the Treasury determines that they knowingly… Read more

542. How does OFAC interpret the following terms as used in section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated into § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR): “significant transaction,” “significant financial transaction,” and “facilitated?”

542 … “ Significant transaction ” and “ significant financial transaction ”– section 589.413 of the URSR states that for purposes of the UFSA prohibitions in § 589.209 , the Secretary of the Treasury will consider the totality of the facts and circumstances when determining whether transactions or… Read more

820. I am required to submit a rejected transaction report to OFAC, but I do not have all the information that is required to be reported pursuant to 31 CFR § 501.604(b). Am I required to collect such information from my counterparty just to complete my rejected transaction report?

820 … OFAC expects U.S. persons and persons otherwise subject to U.S. jurisdiction to provide all information required by Section 501.604(b) of the RPPR that is in the filer’s possession in a rejected transaction report, and generally does not expect reporters to seek further information from… Read more

827. What does Nicaragua-related General License (GL) 2 authorize with respect to the Nicaraguan National Police?

827 … GL 2 authorizes the wind down of transactions involving the Nicaraguan National Police (NNP), including the processing of salary payments from the NNP to its employees, so long as no other blocked persons are involved in the transaction, through 12:01 a.m. eastern daylight time, May 6, 2020.… Read more

828. I want to help with the humanitarian response to public health concerns, including the Coronavirus Disease 2019 (COVID-19) outbreak, in Iran. What can I do to help while remaining compliant with U.S. sanctions?

828 … There are a number of ways consistent with U.S. sanctions to provide humanitarian goods or assistance to the Iranian people in response to public health concerns in Iran, including the COVID-19 outbreak. The making of humanitarian donations to recipients in Iran from the United States or by… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence