Frequently Asked Questions

1111. What does Global Magnitsky General License 5 Authorizing Certain Transactions Related to Frigorifico Chajha S.A.E. authorize?

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 facilitation… Read more

1113. If a decedent’s estate includes securities issued by non-blocked Russian entities, do the new investment prohibitions in Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 prohibit the transfer of such securities, through inheritance, to the relevant beneficiary of the decedent’s estate?

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 part of… Read more

1114. What actions were taken on February 24, 2023 related to the metals and mining sector of the Russian Federation economy?

On February 24, 2023, the Director of OFAC, in consultation with the Department of State, issued a sectoral determination pursuant to Executive Order (E.O.) 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the metals and mining… Read more

1115. For the purposes of the determination of February 24, 2023 made pursuant to Executive Order (E.O.) 14024, what is meant by the term “metals and mining sector of the Russian Federation economy”?

For the purposes of the determination of February 24, 2023 made pursuant to E.O. 14024 , OFAC anticipates publishing regulations defining the term “metals and mining sector of the Russian Federation economy” to include any act, process, or industry of extracting, at the surface or underground, ores… Read more

1116. Does the determination of February 24, 2023 made pursuant to Executive Order (E.O.) 14024 with regard to the metals and mining sector of the Russian Federation economy mean that all persons that operate or have operated in this sector of the Russian Federation economy are sanctioned by OFAC?

No. The Director of OFAC, in consultation with the State Department, has issued a determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy. A… Read more

1056. What does the June 9, 2022 amendment to the Cuban Assets Control Regulations (CACR) do?

Effective June 9, 2022, in consultation with the Department of State, OFAC amended the CACR to implement elements of policy changes announced by the Administration on May 16, 2022 to increase support for the Cuban people. Professional meetings and conferences in Cuba: Effective June 9, 2022, OFAC… Read more

1057. Are remittance forwarding service providers required to independently verify that a sender’s family or donative remittance is authorized when processing such remittances?

No. Under 31 CFR § 515.572(a)(3) , banking institutions, as defined in § 515.314 , including U.S.-registered brokers or dealers in securities and U.S.-registered money transmitters, are authorized to provide services in connection with the collection, forwarding, or receipt of remittances… Read more

1064. Are executive search and vetting services included in the prohibition on management consulting services imposed by the determination made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services”?

Yes. For the purposes of this determination, OFAC interprets management consulting services to include services related to strategic business advice; organizational and systems planning, evaluation, and selection; development or evaluation of marketing programs or implementation; mergers,… Read more

1065. Do the prohibitions imposed by the determination made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” prohibit U.S. persons from serving as voting trustees on behalf of, or for shares of, persons located in the Russian Federation?

Yes, unless otherwise exempt or authorized by OFAC. …

1066. Do the prohibitions imposed by the determination made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” prohibit the provision of educational services, such as online university courses, on the subjects of accounting, management consulting, or trust and corporate formation to persons located in the Russian Federation?

No, provided such services do not evade or avoid the prohibition on providing the underlying services to persons located in the Russian Federation. …

Frequently Asked Questions

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