Frequently Asked Questions

680. Does the blocking of the Government of Venezuela impact the ability of U.S. persons to transact with the Government of Venezuela, or persons in which the Government of Venezuela owns, directly or indirectly, a 50 percent or greater interest?

Yes. Unless exempt or authorized by OFAC, all property and interests in property of persons meeting the definition of the Government of Venezuela (see section 6(d) of E.O. 13884 of August 5, 2019) that are in, or come within, the United States or the possession or control of a United States person… Read more

681. Does General License 28 extend the authorization of wind-down periods that have expired for Petroleos de Venezuela, S.A. (PdVSA), Banco Central de Venezuela (BCV), or other blocked Government of Venezuela persons?

No. General License 28, “Authorizing Certain Activities Necessary to the Wind Down of Operations or Existing Contracts Involving the Government of Venezuela,” only authorizes dealings with persons blocked solely pursuant to E.O. of August 5, 2019; General License 28 does not authorize dealings with… Read more

803. What types of activity does General License 35 authorize?

U.S. persons are authorized to engage in certain administrative transactions with the Government of Venezuela that are prohibited by E.O. 13884 of August 5, 2019, where such transactions are necessary and ordinarily incident to such persons’ day-to-day operations. General License 35 authorizes U.S… Read more

808. Do I need a specific license from OFAC to file a suit in U.S. court against a person designated or blocked pursuant to Venezuela-related sanctions? Does a U.S. court, or its personnel, need a specific license from OFAC to hear such a case?

No. A specific license from OFAC is not required to initiate or continue U.S. legal proceedings against a person designated or blocked pursuant to the Venezuela Sanctions Regulations, 31 CFR part 591 (VSR), or for a U.S. court, or its personnel, to hear such a case. Similarly, creditors may file… Read more

149. What activities by foreign financial institutions can subject them to CISADA sanctions?

As described in the Iranian Financial Sanctions Regulations , the sanctionable activities of a foreign financial institution are: Facilitating the efforts of the Government of Iran (GOI) to acquire or develop Weapons of Mass Destruction (WMD) or delivery systems for WMD or to provide support for… Read more

150. Where can I find a list of Islamic Revolutionary Guard Corps (IRGC) affiliates and Iran-linked financial institutions “blocked pursuant to the International Emergency Economic Powers Act (IEEPA)”?

The list of blocked IRGC affiliates and blocked Iran-linked financial institutions is dynamic and is based on the identity of “designated” persons, which refers both to natural persons (i.e., individuals) and legal persons (such as corporations and other entities). The most recent list of… Read more

151. How do the Iranian Financial Sanctions Regulations (IFSR) define “U.S. financial institutions”?

The Iranian Financial Sanctions Regulations (IFSR) define “U.S. financial institutions” to include: depository institutions, banks, savings banks, money service businesses, trust companies, insurance companies, securities brokers and dealers, commodities exchanges, clearing corporations, investment… Read more

152. How do the Iranian Financial Sanctions Regulations (IFSR) define “foreign financial institutions”?

The Iranian Financial Sanctions Regulations (IFSR) define “ foreign financial institutions ” to include foreign depository institutions, banks, savings banks, money service businesses, trust companies, securities brokers and dealers, commodities exchanges, clearing corporations, investment… Read more

153. How do the Iranian Financial Sanctions Regulations (IFSR) define the term “knowingly”?

The term “knowingly” as used in the IFSR means that a person has actual knowledge or should have known of specific conduct, a circumstance, or a result. In other words, the IFSR could be implicated if the Treasury Department finds that a foreign financial institution knew or should have known that… Read more

154. How does the Treasury Department determine whether a transaction or financial service is “significant” for purposes of the Iranian Financial Sanctions Regulations (IFSR)?

As set out in the IFSR , in determining whether a transaction or financial service is “ significant ,” the Treasury Department may consider: (1) the size, number, frequency, and nature of the transaction(s); (2) the level of awareness of management of the transaction(s) and whether or not the… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence