Frequently Asked Questions

982. Are U.S. funds allowed to buy or sell debt or equity of blocked Russian financial institutions? Are U.S. investors allowed to invest in a fund that holds debt or equity of a blocked Russian financial institution?

982 … Unless otherwise authorized, U.S. persons may not buy or sell debt or equity of the Russian financial institutions blocked pursuant to Executive Order (E.O.) 14024 . Accordingly, a U.S. fund may not buy, sell, or otherwise engage in transactions related to debt or equity of such blocked… Read more

983. What actions did the Office of Foreign Assets Control (OFAC) take in February 2022 with respect to new debt or equity restrictions pursuant to Executive Order (E.O.) 14024?

983 … In February 2022, OFAC issued two directives under E.O. 14024 regarding restrictions related to new debt or equity involving certain Russian Federation or Russia-related entities: On February 22, 2022, OFAC issued Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt… Read more

965. How does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) change prohibitions relating to U.S. financial institution dealings in Russian sovereign debt pursuant to Directive 1 under E.O. 14024 of April 15, 2021?

965 … Directive 1 under E.O. 14024 of April 15, 2021 imposed prohibitions on participation in the primary market for ruble or non-ruble denominated bonds issued by, or the lending of ruble or non-ruble denominated funds to, the Central Bank of the Russian Federation, the National Wealth Fund of the… Read more

985. Does the 50 Percent Rule apply to Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive)?

985 … Yes. The prohibitions of the Russia-related Entities Directive apply to any entity listed in Annex 1 to the Russia-related Entities Directive or otherwise determined to be subject to the prohibitions of the Russia-related Entities Directive, or their property or interests in property, which… Read more

986. What constitutes debt or equity for purposes of Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive)?

986 … The term “debt” includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper. The term “equity” includes stocks, share issuances, depositary receipts, or any other evidence of title or ownership… Read more

1030. What obligations do operators of credit card systems have under the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. part 587 (RuHSR), and the Belarus Sanctions Regulations, 31 C.F.R. part 548 (BSR), with regard to payment cards issued by sanctioned Russian financial institutions?

1030 … Pursuant to the RuHSR and BSR, U.S. persons, including U.S. operators of credit card systems and U.S. acquirers, are prohibited from processing transactions involving certain sanctioned foreign financial institutions, unless exempt or authorized by OFAC. Non-U.S. operators of credit card… Read more

956. For the Belarus, Russian Harmful Foreign Activities (Russia) Ukraine-/Russia-related, and Venezuela-related sanctions programs, how does OFAC view modifications to pre-existing loans, contracts, or other agreements to replace London Interbank Offered Rate (LIBOR) as the reference rate?

956 … In July 2017, the United Kingdom Financial Conduct Authority (FCA) announced the “future cessation and loss of representativeness” of the ICE Benchmark Administration’s 35 global reference rates, the LIBOR rates. In light of the discontinuation of LIBOR as a benchmark reference rate, OFAC is… Read more

957. Can non-U.S. companies ship food and agricultural products to Afghanistan? Can banks process these transactions?

957 … Yes. Both U.S. and non-U.S. companies can ship food to Afghanistan, and banks can process financial transfers and other transactions associated with food shipments to Afghanistan. As described in FAQ 930 , U.S. sanctions do not specifically prohibit the exportation or reexportation of… Read more

958. What are examples of transactions involving the Taliban or the Haqqani Network that are authorized under Afghanistan-related General Licenses (GLs) 14 and 19? Are such transactions covered by Afghanistan-related GL 20?

958 … As one example, if a non-governmental organization is providing support directly to Afghan hospitals or healthcare workers but needs to sign a memorandum of understanding that involves the Taliban in order to provide such support directly to the Afghan people, this engagement would be… Read more

959. Is support to public hospitals in Afghanistan (e.g., health services, facilities maintenance, and health worker salaries) by nongovernmental organizations (NGOs) considered ordinarily incident and necessary to authorized activities under Afghanistan-related General Licenses (GLs) 14, 15, and 19? Are such transactions covered by Afghanistan-related GL 20?

959 … Yes. Providing support to public hospitals, such as provision of health services, technical support, and institutional deliveries, as well as payments directly to healthcare workers, that would otherwise be prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR),… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence