Frequently Asked Questions

1179. What type of small businesses are considered an “independent private sector entrepreneur” (as defined in 31 CFR § 515.340)?

1179 … Section 515.340 defines the term “independent private sector entrepreneur” to mean a Cuban national who is not a prohibited official of the Government of Cuba or a prohibited member of the Cuban Communist Party, and who is one or more of the following: (a) an owner, including a self-… Read more

1181. Effective June 12, 2024, how is Treasury interpreting Russia’s military-industrial base under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?

1181 … In line with G7 commitments and in response to the Government of the Russian Federation’s continued efforts to reorient its economy and government resources to support its war effort, Treasury has updated its definition of Russia’s military-industrial base to include all persons blocked… Read more

1182. Are foreign financial institutions (FFIs) subject to sanctions risk for providing all financial services involving persons blocked pursuant to Executive Order (E.O.) 14024, as amended? What about agricultural, medical, and other transactions authorized by OFAC General Licenses?

1182 … Treasury remains focused on counteracting activity that involves sanctions evasion or third-country support to Russia's military-industrial base. At the same time, legitimate humanitarian activity and agricultural and medical trade are not the target of our sanctions. Accordingly, FFIs may… Read more

1184. What action did Treasury take on June 12, 2024 with regards to prohibiting certain information technology (IT) and software-related services?

1184 … In line with G7 efforts to disrupt Russia’s defense industry’s reliance on western IT systems, on June 12, 2024, Treasury issued a determination that restricts the provision of certain IT and software-related services to Russia. The determination, “ Prohibition on Certain Information… Read more

1185. What activities are considered prohibited “information technology (IT) consultancy and design services” under the determination, “Prohibition on Certain Information Technology and Software Services,” pursuant to Executive Order (E.O. 14071) (the “IT and Software Services Determination”)?

1185 … IT consultancy and design services include the development and implementation of software, as well as assistance or advice relating to the development and implementation of software, including the supply and installation of bespoke software. However, the retail sale of off-the-shelf… Read more

1186. What activities are considered prohibited “IT support services” and “cloud-based services” for enterprise management software and design and manufacturing software (collectively “Covered Software”) under the determination, “Prohibition on Certain Information Technology and Software Services”, pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”)?

1186 … The IT and Software Services Determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of both IT support services and cloud-based services for the Covered Software to a person… Read more

1187. How does OFAC intend to interpret the following terms in the determination, “Prohibition on Certain Information Technology and Software Services,” pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”): “enterprise management software,” “design and manufacturing software,” “cloud-based services,” “information technology support services,” and “information technology consultancy and design services”?

1187 … OFAC expects to promulgate regulations that define or interpret these terms as follows: The term enterprise management software means the following types of software: enterprise resource planning (ERP), customer relationship management (CRM), business intelligence (BI), supply chain… Read more

1188. Does the determination, “Prohibition on Certain Information Technology and Software Services,” pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”) prohibit U.S. persons from providing services to persons located outside of the Russian Federation that are owned or controlled by persons located in the Russian Federation?

1188 … No, provided that the provision of services is not an indirect export to a person located in the Russian Federation. For the purposes of the IT and Software Services Determination , OFAC interprets the “indirect” provision of the prohibited services to include when the benefit of the… Read more

1146. What does Executive Order (E.O.) 14114, “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities,” do?

1146 … E.O. 14114 amends E.O. 14024 and E.O. 14068 to further address the Russian Federation’s continued use of its military-industrial base to aid its effort to undermine security in countries and regions important to United States national security and to further counteract the Russian Federation… Read more

1147. How does Executive Order (E.O.) 14114 amend E.O. 14024, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation”?

1147 … E.O. 14114 amends E.O. 14024 to authorize the imposition of sanctions on foreign financial institutions (FFIs) that have engaged in certain transactions involving Russia’s military-industrial base, including all persons whose property and interests in property are blocked pursuant to E.O.… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence