Frequently Asked Questions

653. I am the manager of a Synthetic Exchange Traded Fund (ETF), which tracks a basket of debt, equity or other holdings in order to provide a return approximating the returns on that basket, but which does not actually hold the underlying debt, equity, or other holdings contained in the basket. May I continue to offer such funds, and may U.S. persons trade in shares of these funds, if the underlying basket being tracked contains holdings in an entity or entities that appear on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), or of an entity owned 50 percent or more, individually or in the aggregate, by an individual or entity on the SDN List?

… List of Specially Designated Nationals and Blocked Persons (SDN List), or of an entity owned 50 percent or more, individually or in the aggregate, by an individual or entity on the SDN List? … List of Specially Designated Nationals and Blocked Persons (SDN List), or of an entity… Read more

589. Will foreign persons be subject to sanctions under the Section 5 of the Ukraine Freedom Support Act (UFSA) or Section 10 of the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act (SSIDES), as amended, respectively, by Sections 226 or Section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) for engaging in activities with GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest?

… in activities with GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest? … in activities with GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest? …

1069. What does Nicaragua General License (GL) 3 authorize?

… de Minas (ENIMINAS), or any entity in which ENIMINAS owns, directly or indirectly, a 50 percent or greater interest (collectively, “Blocked ENIMINAS Entities”), through 12:01 a.m. … de Minas (ENIMINAS), or any entity in which ENIMINAS owns, directly or indirectly, a 50… Read more

988. Does Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prohibit U.S. persons from engaging in all activities with entities subject to it?

… as explained in FAQ 984 . Please see FAQ 985 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive. Some entities determined to be subject to the … as explained in FAQ 984 . Please see FAQ 985 regarding the applicability of OFAC’s 50… 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?

… and involve Gazprombank, or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest, or are prohibited by Directive 4 under E.O. 14024 , "Prohibitions … and involve Gazprom Neft, or any entity in which Gazprom Neft owns, directly 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?

… in which Orka Holding AD owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. Non-U.S. persons generally do not risk exposure to sanctions for … in which Orka Holding AD owns, directly or indirectly, individually or in the aggregate, a… Read more

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

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

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

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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence