Frequently Asked Questions

903. Do the prohibitions of Executive Order (E.O.) 13959, as amended, apply to U.S. persons who are employed by non-U.S. entities and who, in the ordinary course of their employment, are involved in purchases or sales of Chinese Military-Industrial Complex Companies’ (CMICs) securities on behalf of their non-U.S. employer?

903 … For purposes of E.O. 13959, as amended, U.S. persons employed by non-U.S. entities are not prohibited from being involved in, or otherwise facilitating, purchases or sales related to a covered security on behalf of their non-U.S. employer, provided that such activity is in the ordinary course… Read more

904. Under Executive Order (E.O.) 13959, as amended, are U.S. market makers permitted to facilitate divestment from publicly traded securities of Chinese Military-Industrial Complex Companies (CMICs)?

904 … Yes. U.S. market makers, and non-U.S. market makers who employ U.S. persons, are permitted to engage in activities that are necessary to effect divestiture during the during the 365-day periods in which divestment transactions are permitted or that are not otherwise prohibited under E.O.… Read more

905. Does Executive Order (E.O.) 13959, as amended, prohibit U.S. persons from engaging in all activities with companies listed on the Non-SDN Chinese Military-Industrial Complex Companies List (the "NS-CMIC List")?

905 … No. The prohibitions of E.O. 13959, as amended, apply only with respect to certain purchases or sales of publicly traded securities of entities listed on the NS-CMIC List. E.O. 13959, as amended, does not prohibit activity with entities listed on the NS-CMIC List that is unrelated to such… Read more

912. What does Belarus General License 3 (GL 3), “Authorizing Certain Transactions with the State Security Committee of the Republic of Belarus,” authorize?

912 … Belarus GL 3 authorizes transactions and activities with the State Security Committee of the Republic of Belarus (the Belarusian KGB) that are necessary and ordinarily incident to requesting, receiving, utilizing, paying for, or dealing in certain licenses and authorizations for the… Read more

913. Does Belarus GL 3 authorize the exportation of hardware or software to the Belarusian KGB, or where the Belarusian KGB is the end user of such hardware and software?

913 … No. Belarus GL 3 does not authorize the exportation, reexportation, or provision of any goods, technology, or services to the Belarusian KGB or any other blocked person, except for the limited purposes of complying with rules and regulations administered by, and certain actions and… Read more

914. Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions and activities that would be authorized for U.S. persons pursuant to Venezuela General License (GL) 40C?

914 … No. Non-U.S. persons would not risk exposure under U.S. sanctions for engaging in activities or facilitating transactions or payments for such activities that would be authorized for U.S. persons pursuant to Venezuela GL 40C . … Do non-U.S. persons risk exposure to U.S. sanctions for engaging… Read more

915. For purposes of Venezuela General License (GL) 40C, what is liquefied petroleum gas?

915 … For purposes of Venezuela GL 40C , the term liquefied petroleum gas refers to the definition provided by the U.S. Energy Information Administration – a group of hydrocarbon gases, primarily propane, normal butane, and isobutane, derived from crude oil refining or natural gas processing. These… Read more

1216. What action has Treasury taken with regard to the provision of petroleum services to Russia?

1216 … In line with G7 efforts to reduce Russian revenues from energy, on January 10, 2025, Treasury issued a determination pursuant to Executive Order (E.O.) 14071 prohibiting petroleum services to Russia. See The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition… Read more

1080. I am a U.S. person with an account at a Russian financial institution blocked pursuant to Executive Order (E.O.) 14024. What am I required or allowed to do under OFAC sanctions with respect to such accounts?

1080 … Since Russia's further invasion of Ukraine beginning in February 2022, OFAC has blocked a number of Russian financial institutions pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy (see FAQ 966 ). In addition, all… Read more

843. I'm a U.S. person that relied on general or specific licenses issued pursuant to the Iranian Transactions and Sanctions Regulations (ITSR) to conduct humanitarian-related or other transactions and activities prior to the identification of the financial sector of Iran and sanctioning of a number of Iranian financial institutions (Iranian FIs) under E.O. 13902. Is any further authorization needed to conduct such transactions following these actions?

843 … No. General License (GL) L extends authorizations provided through specific and general licenses issued under the ITSR to apply to transactions and activities involving Iranian FIs blocked pursuant to E.O. 13902 . Further authorization from OFAC beyond GL L is not required under E.O. 13902,… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence