Frequently Asked Questions

1109 … No, provided the petroleum products are unloaded at the port of destination prior to 12:01 a.m., eastern daylight time, April 1, 2023.  Petroleum products of Russian Federation origin that are loaded onto a vessel at the port of loading prior to 12:01 a.m., eastern standard time, February 5… Read more

1110 … On May 17, 2024, OFAC amended 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) to incorporate the provisions of General License (GL) D-2 into 31 CFR § 560.540, with certain additional amendments. Section 560.540 supersedes GL D-2, which OFAC issued on September… Read more

1111 … On January 26, 2023, OFAC designated Frigorifico Chajha S.A.E. (Frigorifico Chajha), pursuant to E.O. 13818 .  Concurrent with this action, OFAC issued General License (GL) 5 , which authorizes certain transactions ordinarily incident and necessary to the divestment or transfer, or the… Read more

1113 … No.  U.S. persons, including U.S. financial institutions, may transfer securities issued by non-blocked Russian entities from a decedent’s estate to the account of a relevant beneficiary or beneficiaries, including a successor entity (e.g., a family trust), provided such transfers (i) are… Read more

939 … GL 5 authorizes, through 12:01a.m. eastern standard time, April 1, 2022, all transactions and activities prohibited by Executive Order (E.O.) 14038 that are ordinarily incident and necessary to the wind down of transactions involving Open Joint Stock Company Belarusian Potash Company (BPC) or… Read more

940 … Pursuant to Directive 1 under E .O. 14038 , the following activities by U.S. persons or within the United States are prohibited, except to the extent provided by law or unless licensed or otherwise authorized by the Office of Foreign Assets Control:  all transactions in, provision of… Read more

941 … Yes. … Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in dealings in both the primary and secondary markets for new debt with a maturity of greater than 90 days issued on or after December 2, 2021 by the Ministry of Finance of the Republic of Belarus or the Development… Read more

942 … No, so long as the terms of such debt (including the repayment period, the interest rate, and the amount) were contractually agreed to before December 2, 2021 and are not modified on or after December 2, 2021. … Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in dealings… Read more

943 … No.  The prohibitions in Directive 1 do not apply to any entity that is owned, directly or indirectly, 50 percent or more by the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus, whether individually or in the aggregate. … Does the 50 Percent… Read more

944 … The term debt includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers’ acceptances, discount notes or bills, or commercial paper. … What constitutes “debt” pursuant to Directive 1 under E.O. …