Frequently Asked Questions

416. What does the "sanctions effective date" mean in the context of sectoral sanctions pursuant to E.O. 13662?

416 … For purposes of the sectoral sanctions, "sanctions effective date" means the date a person is determined to be subject to the prohibition(s) of the relevant Directive . When a person has been previously determined to be subject to a Directive and the prohibitions in the Directive are… Read more

418. How does OFAC interpret the term "shale projects" with respect to the prohibitions in Directive 4, now incorporated into § 589.205 of the Ukraine-/Russia-Related Sanctions Regulations (URSR)?

418 … The term "shale projects," as defined in § 589.334 of the URSR, includes projects that have the potential to produce oil from resources located in shale formations as well as projects that have the potential to produce oil from resources located in fine-grained sedimentary rock formations… Read more

419. How should U.S. persons account for the debt prohibitions under Directives 1, 2, and 3 as they relate to payment terms for the following types of transactions: (1) the sale of goods to an SSI entity, (2) the provision of services to and subscription arrangements involving SSI entities, and (3) progress payments for long-term projects?

419 … U.S. persons may engage in commercial transactions with SSI entities provided that any such transactions do not represent a direct or indirect dealing in prohibited debt or equity. Because offering payment terms of longer than the applicable tenor specified in the relevant Directive to an SSI… Read more

420. Under Directive 4, does the term "production" encompass activities such as transportation, refining, or other dealings in oil extracted from deepwater, Arctic offshore, or shale projects?

420 … For the purposes of Directive 4 , the term "production" refers to the lifting of oil to the surface and the gathering, treating, field processing, and field storage of such oil. The production stage of a project ends when extracted oil is transported out of a field production storage tank or… Read more

543. How will U.S. financial institutions and foreign financial institutions (FFIs) know that the Department of the Treasury has imposed prohibitions or strict conditions on FFIs’ correspondent accounts or payable-through accounts in the United States pursuant to section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated in § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR)?

543 … If, pursuant to § 589.209 of the URSR, Treasury decides to impose strict condition(s) on maintaining U.S. correspondent accounts or U.S. payable-through accounts for an FFI, or decides to prohibit the opening or maintaining of U.S. correspondent accounts or U.S. payable-through accounts for… Read more

544. What is the relationship between CAATSA and the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES)?

544 … Section 228 of CAATSA adds two sections to SSIDES that impose mandatory sanctions. … What is the relationship between CAATSA and the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 …

545. What do the following key terms in section 10 of the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES), as amended by section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), mean: “foreign person,” “knowingly,” “materially violate,” “facilitates . . . for or on behalf of,” “significant transaction,” and “deceptive or structured transaction”?

545 … “foreign person” – As stated in § 589.317 of the Ukraine-/Russia-Related Sanctions Regulations (URSR), the term foreign person for purposes of the SSIDES section 10 provisions in §§ 589.201(a)(6) and 589.413 means any citizen or national of a foreign state (including any such individual who… Read more

546. In section 10(a)(2)(A) of the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES), as amended by section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), and implemented in § 589.201(a)(6)(vii)(B)(1) of the Ukraine-/Russia-Related Sanctions Regulations (URSR), are persons “subject to sanctions imposed by the United States with respect to the Russian Federation” limited to persons listed on OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List, or does it also include persons identified on the Sectoral Sanctions Identifications (SSI) List, Non-SDN Menu-Based Sanctions (NS-MBS) List, or other OFAC sanctions lists?

546 … For purposes of section 10(a)(2)(A) of SSIDES and § 589.201(a)(6)(vii)(B)(1) of the URSR, OFAC will interpret the phrase “subject to sanctions imposed by the United States with respect to the Russian Federation” to be persons subject to sanctions under SSIDES, as amended, the Ukraine Freedom… Read more

552. Has the Treasury Department now sanctioned the individuals and entities included in its January 29, 2018 report on senior political figures, oligarchs, and parastatal entities of the Russian Federation?

552 … No. Pursuant to section 241 of Countering America’s Adversaries Through Sanctions Act of 2017 (Pub. L. 115-44), the Treasury Department, in consultation with Secretary of State and the Director of National Intelligence, delivered a report on January 29, 2018 to the specified congressional… Read more

627. What is the purpose of the Executive Order (E.O.) of September 20, 2018, “Authorizing the Implementation of Certain Sanctions Set Forth in the Countering America’s Adversaries Through Sanctions Act”?

627 … Title II of the Countering America’s Adversaries Through Sanctions Act, as amended ( CAATSA ), and the Ukraine Freedom Support Act of 2014, as amended ( UFSA ), provide for the imposition of certain sanctions with respect to the Russian Federation. The E.O. of September 20, 2018 provides… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence