Frequently Asked Questions

610. What is considered Iran’s automotive sector for purposes of E.O. 13846?

610 … E.O. 13846 defines the automotive sector of Iran as the manufacturing or assembling in Iran of light and heavy vehicles including passenger cars, trucks, buses, minibuses, pick-up trucks, and motorcycles, as well as original equipment manufacturing and after-market parts manufacturing… 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

673. What is the purpose of Executive Order (E.O.) 13883, “Administration of Proliferation Sanctions and Amendment of Executive Order 12851”?

673 … E.O. 13883 delegates to the Secretary of the Treasury the implementation of the sanctions related to multilateral development bank assistance and to United States bank loans that are contained in the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991, as amended (“CBW… Read more

674. What action did the U.S. government take under the CBW Act on August 2, 2019?

674 … Following the chemical weapons attack in Salisbury, United Kingdom, the Department of State, acting under the CBW Act pursuant to authority delegated to the Secretary of State, made a determination on August 6, 2018 that the Government of the Russian Federation had used chemical weapons in… Read more

675. How does OFAC implement sanctions related to U.S. bank loans imposed on Russia pursuant to the CBW Act?

675 … Pursuant to Executive Order (E.O.). 13883 , 31 CFR § 544.802, and the CBW Act, on August 2, 2019, OFAC issued a Russia-Related Directive (the “CBW Act Directive”) , which prohibits U.S. banks from participating in the primary market for non-ruble denominated bonds issued by the Russian… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence