Frequently Asked Questions

1117. My company provides goods or services to, or engages in trade with, persons that operate or have operated in the metals and mining sector of the Russian Federation economy. Does my company risk being sanctioned by OFAC?

1117 … The determination made on February 24, 2023 pursuant to Executive Order (E.O.) 14024 authorizes sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy. Non-U.S. persons may also be exposed to sanctions for activities… Read more

1118. As of December 2022, the Government of the Russian Federation may require a so-called "exit tax" payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called "exit tax"? Does Russia-related General License (GL) 13M authorize transactions that involve the payment of this exit tax?

1118 … The Directive 4 under Executive Order (E.O.) 14024, "Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation," as amended ( Russia-related Sovereign… Read more

1119. Does General License (GL) O authorize all wind-down transactions for any vessel that was blocked on March 2, 2023? What if the vessel contains Iranian-origin merchandise?

1119 … Iran GL O authorizes U.S. persons to wind down all transactions otherwise prohibited by section 5 of Executive Order 13846 involving any vessel blocked as part of the March 2, 2023 designation (“blocked vessels”), subject to certain conditions. This includes, among other activities, the… Read more

1120. Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions that U.S. persons would be authorized to engage in under Iran General License (GL) O?

1120 … No. Non-U.S. persons generally do not risk exposure to sanctions for engaging in activities or facilitating transactions for such activities that would be authorized for U.S. persons pursuant to GL O . Non-U.S. persons unable to wind down transactions in accordance with Iran GL O before 12… Read more

1131. Is LETTERONE HOLDINGS S.A. (LetterOne) blocked as a result of the designation of Petr Olegovich Aven, Mikhail Maratovich Fridman, German Borisovich Khan, and Alexey Viktorovich Kuzmichev?

1131 … No. OFAC has not designated LetterOne and, based on information available to OFAC, LetterOne is not owned 50 percent or more by blocked persons or otherwise considered the blocked property or interest in property of blocked persons, including Petr Olegovich Aven, Mikhail Maratovich Fridman… Read more

1132. Does the determination of August 23, 2023, made pursuant to Executive Order (E.O.) 14014 with regard to the jet fuel sector of the Burmese economy mean that all persons that operate or have operated in this sector of the Burmese economy are sanctioned by OFAC?

1132 … No. The OFAC Director, in consultation with the Department of State, has issued a determination pursuant to E.O. 14014 that authorizes the imposition of economic sanctions on any foreign person determined to operate in the jet fuel sector of the Burmese economy. A sector determination… Read more

1133. For the purposes of the determination of August 23, 2023, made pursuant to Executive Order (E.O.) 14014, what is meant by the term “jet fuel sector of the Burmese economy”?

1133 … For the purposes of the determination of August 23, 2023 made pursuant to E.O. 14014 , OFAC interprets the term “jet fuel sector of the Burmese economy” to include activities related to the importation, exportation, reexportation, sale, supply, or transport, directly or indirectly, of jet… Read more

1134. What is the humanitarian channel in Qatar?

1134 … The humanitarian channel in Qatar (HC) was established to further facilitate the flow of humanitarian assistance to the people of Iran consistent with the U.S. government’s longstanding support for humanitarian trade. Similar to humanitarian channels established under previous… Read more

1135. How can companies participate in the humanitarian channel in Qatar to export humanitarian goods to Iran?

1135 … Financial institutions participating in the humanitarian channel in Qatar (HC) have received specific guidance from the U.S. government. Companies interested in participating in transactions under the HC should coordinate directly with the Qatari International Media Office at info@imo.gov.… Read more

1136. Can U.S. persons purchase bonds issued by the Government of Venezuela or Petróleos de Venezuela, S.A. (PdVSA) prior to August 25, 2017 on the secondary market?

1136 … Yes. On October 18, 2023, OFAC issued amended General Licenses (GLs) 3I and 9H , to remove the restriction that any divestment by U.S. persons of holdings in GL 3I Bonds (as defined in GL 3I and FAQ 662 ) or PdVSA Securities (as defined in GL 9H and FAQ 661 ) must be to non-U.S. persons. GL… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence