Frequently Asked Questions

1135. How can companies participate in the humanitarian channel in Qatar to export humanitarian goods to Iran?

Financial institutions participating in the humanitarian channel in Qatar (HC) have received specific guidance from the U.S. government. Companies interested in participating in transactions under the HC should coordinate directly with the Qatari International Media Office at info@imo.gov.qa and… Read more

1136. Can U.S. persons purchase bonds issued by the Government of Venezuela or Petróleos de Venezuela, S.A. (PdVSA) prior to August 25, 2017 on the secondary market?

Yes. On October 18, 2023, OFAC issued amended General Licenses (GLs) 3I and 9H , to remove the restriction that any divestment by U.S. persons of holdings in GL 3I Bonds (as defined in GL 3I and FAQ 662 ) or PdVSA Securities (as defined in GL 9H and FAQ 661 ) must be to non-U.S. persons. GL 3I… Read more

1137. For purposes of General License (GL) 45B, “Authorizing Certain Repatriation Transactions Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A.,” what countries are included in the “Western Hemisphere”?

For the purposes of GL 45B, OFAC considers the term “Western Hemisphere” to mean those countries and areas identified by the Department of State on its website as comprising the Western Hemisphere. Please see: Bureau of Western Hemisphere Affairs - United States Department of State. Date updated… Read more

1139. Does the 50 Percent Rule apply to Directive 1 under Executive Order 14014, “Prohibitions Related to Financial Services to or for the Benefit of Myanma Oil and Gas Enterprise” (MOGE Financial Services Directive)?

Yes. The prohibitions in the MOGE Financial Services Directive apply to MOGE “or its property or interests in property,” including any entity, such as a subsidiary or joint venture, that is 50 percent or more owned, directly or indirectly, by MOGE, except to the extent otherwise provided by law or… Read more

1140. In light of the designation of Orka Holding, are U.S. persons authorized to engage in transactions related to the provision of medicine, medical devices, and medical services involving Orka Holding and its subsidiaries?

Yes. As a general matter, humanitarian trade is not the target of U.S. sanctions. Concurrent with the designation of Orka Holding AD, OFAC issued Western Balkans General License (GL) 3 , which authorizes all transactions involving Orka Holding AD related to: (1) the production, manufacturing,… Read more

1141. Does Venezuela General License (GL) 45B authorize U.S. persons to provide certain services, including refueling services, repair, and maintenance, to blocked Conviasa aircraft that are carrying out flights for the exclusive purpose of repatriating Venezuelan nationals from a third country in the Western Hemisphere to Venezuela?

Yes. Date updated: March 01, 2024 …

1145. What if a governing institution in Afghanistan is led by an individual who has been blocked pursuant to the Global Magnitsky Sanctions Regulations?

Generally, the designation of an individual with a leadership role in a governing institution does not itself block the governing institution. Accordingly, engaging in a routine interaction with a governing institution in which a blocked individual is an official, but that does not directly or… Read more

1146. What does Executive Order (E.O.) 14114, “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities,” do?

E.O. 14114 amends E.O. 14024 and E.O. 14068 to further address the Russian Federation’s continued use of its military-industrial base to aid its effort to undermine security in countries and regions important to United States national security and to further counteract the Russian Federation’s… Read more

1147. How does Executive Order (E.O.) 14114 amend E.O. 14024, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation”?

E.O. 14114 amends E.O. 14024 to authorize the imposition of sanctions on foreign financial institutions (FFIs) that have engaged in certain transactions involving Russia’s military-industrial base, including all persons whose property and interests in property are blocked pursuant to E.O. 14024. … Read more

1148. What activities could expose a foreign financial institution (FFI) to sanctions under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?

FFIs may be sanctioned for engaging in certain transactions, or providing any service, involving Russia’s military-industrial base. For example, FFIs may be sanctioned for conducting any significant transaction(s) for any person that has been blocked pursuant to E.O. 14024. FFIs may also be… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence