Frequently Asked Questions

1151. How does OFAC intend to interpret the following terms in Executive Order (E.O.) 14024, as amended by E.O. 14114: “foreign financial institution,” “Russia’s military-industrial base,” and “significant transaction or transactions”?

1151 … OFAC expects to promulgate regulations that define or interpret these terms as follows: Foreign Financial Institution: As defined in subsection 11(f) of E.O. 14024 , foreign financial institution means any foreign entity that is engaged in the business of accepting deposits, making, granting… Read more

1152. Could foreign financial institutions (FFIs) that engage in transactions in non-USD currencies be sanctioned under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?

1152 … Yes. The prohibitions and targeting authorities of amended section 11 of E.O. 14024 apply with respect to any currency. For example, an FFI that processes a significant transaction denominated in a non-USD local currency for a person blocked pursuant to E.O. 14024 or an FFI that processes… Read more

1154. How does Executive Order (E.O.) 14114 of December 22, 2023 amend E.O. 14068, “Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression”?

1154 … E.O. 14114 of December 22, 2023 amends E.O. 14068 to provide for additional prohibitions on the importation and entry into the United States of certain products. It does so by maintaining the existing E.O. 14068 importation prohibitions in subsection 1(a)(i)(A) and identifying in… Read more

1155. What does the determination of December 22, 2023, “Prohibitions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof,” pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114 of December 22, 2023, (Seafood Determination) prohibit?

1155 … The Seafood Determination issued pursuant to subsection 1(a)(i)(B) of E.O. 14068 , as amended, prohibits the importation and entry into the United States, including importation for admission into a foreign trade zone located in the United States, of salmon, cod, pollock, or crab that was… Read more

1156. I have a shipment of a certain product(s) containing the types of seafood listed in the determination of December 22, 2023 pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114 of December 22, 2023, (Seafood Determination) en route to the United States that was contracted prior to December 22, 2023. Can I complete such import into the United States? Can I find a new buyer for this shipment and/or re-direct the shipment to a country other than the United States?

1156 … Individuals and entities may import the listed types of seafood, for a limited time, into the United States subject to the conditions of General License (GL) 83 . GL 83 authorizes the importation into the United States, through 12:01 a.m. eastern standard time, February 21, 2024, of salmon… Read more

1157. For the purposes of the determination of December 22, 2023 pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114 of December 22, 2023, (Seafood Determination) what is meant by the terms “salmon,” “cod,” “pollock,” and “crab”?

1157 … For the purposes of the Seafood Determination , OFAC anticipates publishing regulations defining these terms to include articles defined at the following Harmonized Tariff Schedule of the United States (HTSUS) subheadings: • “Salmon:” articles defined at HTSUS subheadings 0302.13.0013,… Read more

1159. What transactions does Global Terrorism Sanctions Regulations (GTSR) General License (GL) 27 authorize?

1159 … Wind down transactions: GL 27 authorizes all transactions prohibited by the GTSR that are ordinarily incident and necessary to the wind down of any transaction involving Fly Baghdad through 12:01 a.m. eastern daylight time, March 22, 2024, provided that any payment to Fly Baghdad must be… 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

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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence