Frequently Asked Questions

1093. What does Nicaragua General License (GL) 4 authorize?

… Ministry of Energy and Mines, or any entity in which DGM owns, directly or indirectly, a 50 percent or greater interest (collectively, “Blocked DGM Entities”), through 12:01 a.m. eastern … Ministry of Energy and Mines, or any entity in which DGM owns, directly or indirectly, a… Read more

249. How is the Score calculated?

… matches based on the first letter of input search terms and by checking for matches at least 50% or more similar based on edit distance (edit distance is the minimum number of operations … matches based on the first letter of input search terms and by checking for matches at… Read more

840. If an official of the Government of the Hong Kong Special Administrative Region (HKSAR) is designated as a Specially Designated National (SDN), does that mean that the HKSAR government is blocked? What are the prohibitions on U.S. persons dealing with a designated HKSAR government official?

… HKSAR government officials, including any entities that are directly or indirectly owned 50 percent or more in the aggregate by one or more blocked persons. U.S. persons should be … HKSAR government officials, including any entities that are directly or indirectly owned … Read more

1149. What sanctions can be imposed on a foreign financial institution (FFI) that engaged in conduct described in section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114? What are the obligations of U.S. financial institutions?

… OFAC. Any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked FFIs (or other blocked persons) are also blocked. … OFAC. Any entities that are owned, directly or indirectly, individually or in the… Read more

954. Are purchases of fuel, payment for telecommunications services, payment for security services, payment of rent, and payment of utilities 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?

… or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. OFAC also issued GL 18 to authorize all transactions that are … or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a… Read more

916. What does Executive Order (E.O.) of August 9, 2021, “Blocking Property of Additional Persons Contributing to the Situation in Belarus,” do?

… authorized by OFAC or otherwise exempt from regulation. Additionally, any entities owned 50 percent or more, individually or in the aggregate, directly or indirectly, by one or more … authorized by OFAC or otherwise exempt from regulation. Additionally, any entities owned… Read more

921. What is the purpose of Executive Order (E.O.) of August 20, 2021, “Blocking Property with Respect to Certain Russian Energy Export Pipelines”?

… generally prohibited from engaging in transactions with them. Additionally, entities owned 50 percent or more, individually or in the aggregate, directly or indirectly, by one or more … generally prohibited from engaging in transactions with them. Additionally, entities owned… Read more

1191. On September 12, 2024, OFAC designated Ly Yong Phat (Ly), L.Y.P. Group Co., LTD (L.Y.P. Group), and the following entities owned by L.Y.P. Group under the Global Magnitsky sanctions authority: O-Smach Resort, Garden City Hotel, Koh Kong Resort, and Phnom Penh Hotel. Can I continue to engage in transactions or other dealings with other entities owned by Ly or L.Y.P. Group that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

… License (GL) 8 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ly or the L.Y.P. Group that is not listed on SDN List. Non-U.S. persons may engage … License (GL) 8 authorizing U.S. persons to engage in all transactions with any entity… Read more

992. What are examples of activities authorized by Afghanistan-related General License (GL) 20, “Authorizing Transactions Involving Afghanistan or Governing Institutions in Afghanistan”?

… or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, or to any blocked individual who is in a leadership role of a … or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a… Read more

560. Are my OFAC compliance obligations the same, regardless of whether a transaction is denominated in digital currency or traditional fiat currency?

… named on OFAC’s SDN List or any entity owned in the aggregate, directly or indirectly, 50 percent or more by one or more blocked persons, and that they do not engage in trade or other … named on OFAC’s SDN List or any entity owned in the aggregate, directly or indirectly,… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence