Frequently Asked Questions

289. How will the following Iran Freedom and Counter-Proliferation Act (IFCA) terms be interpreted: “Iran,” “knowingly,” “significant,” and “transfer”?

As a general matter, we intend to rely, where applicable, on definitions of terms previously included in Treasury regulations. “Iran” The Iranian Financial Sanctions Regulations ( 31 CFR part 561 ) (IFSR) define “Iran” as the Government of Iran and the territory of Iran and any other territory or… Read more

68. If a policyholder becomes a Specially Designated National (SDN) or blocked person after policy issuance, can the insurer notify the policyholder that the policy is now "blocked"?

Yes. The insurer may notify the policyholder that the policy is blocked without obtaining a specific license from OFAC. Date Updated: November 13, 2024 …

69. When notifying a policyholder that their policy is "blocked" due to OFAC sanctions, may the insurer also instruct the policyholder not to send further premium payments or that the insurer will not accept additional premium payments under this account?

The insurer may instruct the policyholder that in accordance with applicable U.S. laws and regulations administered by OFAC, the insurer must place any subsequent premium payments into a blocked account. For funds, such as unearned premium payments, that are blocked in addition to the policy, an… Read more

919. How do sanctions related to U.S. bank loans imposed on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Act of 1991 (CBW Act), as announced by the State Department on August 20, 2021, affect existing prohibitions?

The prohibitions announced by the State Department on August 20, 2021 related to U.S. bank loans have the same scope as those imposed by OFAC in August 2019 under the CBW Act Directive . Please see FAQs 675 – 678 for additional information. Independent of the CBW Act Directive, OFAC has imposed… Read more

920. How are the sanctions related to import restrictions imposed on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Act of 1991 (CBW Act), as announced by the State Department on August 20, 2021, being implemented?

The announced import restrictions related to the permanent importation of firearms and ammunition that are the growth, product, or manufacture of the Russian Federation will be implemented by the U.S. Department of Justice, Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). OFAC has… Read more

921. What is the purpose of Executive Order (E.O.) of August 20, 2021, “Blocking Property with Respect to Certain Russian Energy Export Pipelines”?

The Protecting Europe’s Energy Security Act of 2019, 22 U.S.C. 9526 note, as amended (PEESA), requires the imposition of sanctions with respect to the provision of vessels engaged in specified activities for the construction of certain Russian energy export pipelines, including the Nord Stream 2… Read more

922. What does Executive Order (E.O.) of September 17, 2021, “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” do?

E.O. of September 17, 2021 provides for the imposition of menu-based sanctions on foreign persons determined by the Secretary of the Treasury, in consultation with the Secretary of State, to meet certain criteria under the order, including foreign persons determined to be responsible for or… Read more

923. Do blocking sanctions imposed on persons pursuant to Executive Order (E.O.) of September 17, 2021, “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” automatically apply to entities owned in whole or in part by sanctioned persons?

No. Unless an entity is itself a sanctioned person (as defined in E.O. of September 17, 2021 ) and listed separately on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), it is not blocked pursuant to E.O. of September 17, 2021. OFAC’s 50 Percent Rule does not apply to… Read more

924. Do non-blocking sanctions imposed on persons pursuant to Executive Order (E.O.) of September 17, 2021, “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” automatically apply to entities owned in whole or in part by sanctioned persons?

No. If a person is listed on OFAC’s Non-SDN Menu-Based Sanctions List (NS-MBS List) as subject to only one or more of the sanctions described in section 2(a)(i)(B) – (E) of E.O. of September 17, 2021, these non-blocking sanctions do not apply to an entity owned in whole or in part, individually or… Read more

926. What activities are authorized pursuant to Ethiopia General License (GL) 2, “Certain Transactions in Support of Nongovernmental Organizations’ Activities”?

Ethiopia GL 2 authorizes certain transactions and activities involving nongovernmental organizations’ (NGOs) activities in Ethiopia or Eritrea, including: activities to support humanitarian projects and to meet basic human needs (such as, among other examples provided in GL 2, shelter and… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence