Frequently Asked Questions

1035. For the purposes of Russia-related General License 35 what is meant by the terms “credit rating services” and “auditing services?”

1035 … The term “credit rating services” means services related to assessments of a borrower’s ability to meet financial commitments, including analysis of general creditworthiness or with respect to a specific debt or financial obligation. The term “auditing services” means examination or… Read more

1036. When do the prohibitions imposed by the determination of May 8, 2022 made pursuant to Executive Order (E.O.) 14071, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” take effect?

1036 … The prohibitions imposed by the determination of May 8, 2022 made pursuant to E.O. 14071 take effect at 12:01 a.m. eastern daylight time June 7, 2022. In addition, OFAC has issued General License 34 to authorize all transactions ordinarily incident and necessary to the wind down of the… Read more

1038. For the purposes of the determination of May 8, 2022 made pursuant to Executive Order (E.O.) 14024, what is meant by the terms “accounting,” “trust and corporate formation services,” and “management consulting” sectors of the Russian Federation economy?

1038 … For the purposes of the determination of May 8, 2022 made pursuant to E.O. 14024 , OFAC interprets the following terms to include activities related to products and services in or involving the Russian Federation in the following: “Accounting sector” – includes the measurement, processing,… Read more

1039. Are transactions ordinarily incident and necessary to the exportation or reexportation of agricultural commodities to, from, or transiting the Russian Federation that involve Agropromyshlennyi Kompleks Voronezhskii OOO, Anninskii Elevator OOO, and Azovskaya Zernovaya Kompaniya OOO authorized under OFAC sanctions?

1039 … Yes. On May 8, 2022, OFAC designated Agropromyshlennyi Kompleks Voronezhskii OOO, Anninskii Elevator OOO, and Azovskaya Zernovaya Kompaniya OOO pursuant to Executive Order (E.O.) 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or… Read more

1040. Are transactions related to telecommunications and certain internet-based communications that involve persons designated pursuant to Executive Order 14024 authorized by Russia-related General License (GL) 25G?

1040 … GL 25G authorizes certain transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR). In addition, GL 25G… 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

848. What are the sanctions implications of the Secretary of State’s October 14, 2020 report to Congress pursuant to section 5(a) of the Hong Kong Autonomy Act (HKAA), and subsequent updates of this report, identifying foreign persons that are materially contributing to, have materially contributed to, or attempt to materially contribute to the failure of the Government of China to meet its obligations under the Joint Declaration or the Basic Law?

848 … Pursuant to section 5(a) of the HKAA , the Secretary of State submitted a report (“Section 5(a) Report”) on October 14, 2020 to the appropriate congressional committees and leadership identifying foreign persons that the Secretary of State, in consultation with the Secretary of the Treasury,… Read more

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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence