Frequently Asked Questions

Each Directive operates independently of the others. If a transaction involves a person subject to two Directives, for example, a U.S. person engaging in that transaction must comply with the requirements of both Directives. Exemptions in one Directive apply only to the prohibitions contained in… Read more

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 subsequently… Read more

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 including… Read more

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

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

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 importation,… Read more

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 investigations… Read more

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 …

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 gases… Read more

As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not… Read more