Frequently Asked Questions

1179. What type of small businesses are considered an “independent private sector entrepreneur” (as defined in 31 CFR § 515.340)?

1179 … Section 515.340 defines the term “independent private sector entrepreneur” to mean a Cuban national who is not a prohibited official of the Government of Cuba or a prohibited member of the Cuban Communist Party, and who is one or more of the following: (a) an owner, including a self-… Read more

1180. What changes did OFAC make in the June 5, 2024 regulatory amendments to the Syrian Sanctions Regulations, 31 CFR part 542 (SySR)?

1180 … On June 5, 2024, OFAC, in consultation with the Department of State, amended the SySR to, among other things, incorporate certain sanctions statutes, including the Caesar Syria Civilian Protection Act of 2019, which are designed to deny the Assad Regime the resources it needs to support its… Read more

1201. What authorizations exist for diplomatic or consular missions operating in or outside of Russia and Russian diplomatic or consular missions operating abroad?

1201 … The Office of Foreign Assets Control (OFAC) has issued several authorizations related to U.S. and third-country diplomatic or consular missions operating in or outside of Russia and Russian diplomatic or consular missions operating abroad. Russian Diplomatic or Consular Missions, Wherever… Read more

1202. Following the November 21, 2024 designation of Russian financial institutions, Treasury has now designated a significant number of financial institutions in Russia. Will this negatively impact the processing of personal, non-commercial remittances to or from Russia?

1202 … No. Treasury's sanctions target Russian financial institutions that have continued to help Russia gain access to the critical goods it needs to prosecute its war in Ukraine. As a general matter, personal, non-commercial remittances are not the target of sanctions imposed by the United States… Read more

1203. What does General License (GL) 115A ("Authorizing Certain Transactions Related to Civil Nuclear Energy") authorize with respect to civil nuclear energy-related payments?

1203 … GL 115A generally authorizes certain transactions related to civil nuclear energy involving certain entities that are sanctioned pursuant to Executive Order 14024. Civil nuclear energy means the following activities when undertaken solely to maintain or support civil nuclear energy projects… Read more

1204. On December 27, 2024, OFAC designated Bidzina Ivanishvili (Ivanishvili) pursuant to Executive Order (E.O.) 14024. Can I continue to engage in transactions or other dealings with entities owned by Ivanishvili that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

1204 … Yes. Although transactions or other dealings involving Ivanishvili are generally prohibited as a result of OFAC's designation, OFAC concurrently issued General License (GL) 116 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ivanishvili provided… Read more

1209. Even after the issuance of Syria General License (GL) 24 ("Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances"), may I still rely on existing sanctions authorizations for the provision of humanitarian aid?

1209 … Yes. The authorization in GL 24 may overlap with the authorizations in existing GLs issued under the Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR), including: transactions in… Read more

1211. Can foreign governments or companies donate or provide subsidized fuel to Syria without facing exposure to U.S. sanctions?

1211 … Yes. Syria General License (GL) 24 authorizes transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria. This may include, for example, the donation of gasoline to Syrian… Read more

1210. Does Syria General License (GL) 24 ("Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances") remove the restrictions placed on Syria under the State Sponsor of Terrorism (SST) designation?

1210 … No. SST restrictions on Syria remain in place. … Does Syria General License (GL) 24 ("Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances") remove the restrictions placed on Syria under the State Sponsor of… Read more

1208. Does Syria General License (GL) 24 ("Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances") authorize activities and transactions with a governing institution in Syria run by or led by a designated person?

1208 … Yes. GL 24 authorizes transactions with governing institutions in Syria, with some conditions and exceptions, through July 7, 2025, even if a designated individual has a leadership role in that governing institution. For example, if a company engaging in otherwise authorized activity needs… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence