Frequently Asked Questions

819. Is the June 21, 2019 amendment to the Office of Foreign Assets Control (OFAC)'s Reporting, Procedures and Penalties Regulations in effect? Am I required to comply with all requirements of the amended regulations?

819 … Yes, effective June 21, 2019, OFAC amended the Reporting, Procedures and Penalties Regulations, 31 CFR part 501 (RPPR) , to provide updated instructions and incorporate new requirements for parties filing reports on blocked property, unblocked property, or rejected transactions. In addition,… 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

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

289 … 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… 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"?

68 … Yes. The insurer may notify the policyholder that the policy is blocked without obtaining a specific license from OFAC. Date Updated: November 13, 2024 … If a policyholder becomes a Specially Designated National (SDN) or blocked person after policy issuance, can the insurer notify the… Read more

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?

69 … 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,… 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?

919 … 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… 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?

920 … 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”?

921 … 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… Read more

Frequently Asked Questions

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