Frequently Asked Questions

1002. Can U.S. persons engage in indirect transactions with persons subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)?

1002 … No. The Russia-related Sovereign Transactions Directive prohibits U.S. persons from engaging in any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any… Read more

1003. Are transactions where the Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation serves solely as the operator of a clearing and settlement system authorized?

1003 … Yes. Please see General License 14 and FAQ 999 . … Are transactions where the Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation serves solely as the operator of a clearing and settlement system …

1004. Are U.S. persons required to block transactions involving entities subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)?

1004 … No. Although the prohibitions of the Russia-related Sovereign Transactions Directive effectively immobilize any assets of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, the “… Read more

1005. Does Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive), prohibit trading in the secondary markets for Russian sovereign debt?

1005 … No, the Russia-related Sovereign Transactions Directive does not prohibit trading in the secondary markets for debt or equity of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively… Read more

1006. What does Executive Order (E.O.) 14065 do?

1006 … E.O. 14065 prohibits the following activities with the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine and such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the… Read more

1007. Are U.S. persons authorized to engage in certain activity with the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions")?

1007 … U.S. persons are authorized through a variety of Ukraine-related general licenses (GLs) to support certain humanitarian efforts and other activity in the Covered Regions, including transactions related to the export of food or medicine, the response to the Coronavirus Disease 2019 (COVID-19… Read more

922. What does Executive Order (E.O.) of September 17, 2021, “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” do?

922 … E.O. of September 17, 2021 provides for the imposition of menu-based sanctions on foreign persons determined by the Secretary of the Treasury, in consultation with the Secretary of State, to meet certain criteria under the order, including foreign persons determined to be responsible for or… Read more

923. Do blocking sanctions imposed on persons pursuant to Executive Order (E.O.) of September 17, 2021, “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” automatically apply to entities owned in whole or in part by sanctioned persons?

923 … No. Unless an entity is itself a sanctioned person (as defined in E.O. of September 17, 2021 ) and listed separately on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), it is not blocked pursuant to E.O. of September 17, 2021. OFAC’s 50 Percent Rule does not apply… Read more

924. Do non-blocking sanctions imposed on persons pursuant to Executive Order (E.O.) of September 17, 2021, “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” automatically apply to entities owned in whole or in part by sanctioned persons?

924 … No. If a person is listed on OFAC’s Non-SDN Menu-Based Sanctions List (NS-MBS List) as subject to only one or more of the sanctions described in section 2(a)(i)(B) – (E) of E.O. of September 17, 2021, these non-blocking sanctions do not apply to an entity owned in whole or in part,… Read more

926. What activities are authorized pursuant to Ethiopia General License (GL) 2, “Certain Transactions in Support of Nongovernmental Organizations’ Activities”?

926 … Ethiopia GL 2 authorizes certain transactions and activities involving nongovernmental organizations’ (NGOs) activities in Ethiopia or Eritrea, including: activities to support humanitarian projects and to meet basic human needs (such as, among other examples provided in GL 2, shelter and… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence