Frequently Asked Questions

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

854. What does General License 38 authorize?

… and activities involving CEIEC, or any entity in which CEIEC owns, directly or indirectly, a 50 percent or greater interest (collectively, Blocked CEIEC Entities), through 12:01 a.m. eastern … and activities involving CEIEC, or any entity in which CEIEC owns, directly or… Read more

546. In section 10(a)(2)(A) of the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES), as amended by section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), and implemented in § 589.201(a)(6)(vii)(B)(1) of the Ukraine-/Russia-Related Sanctions Regulations (URSR), are persons “subject to sanctions imposed by the United States with respect to the Russian Federation” limited to persons listed on OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List, or does it also include persons identified on the Sectoral Sanctions Identifications (SSI) List, Non-SDN Menu-Based Sanctions (NS-MBS) List, or other OFAC sanctions lists?

… the authorities listed above, and associated persons subject to sanctions pursuant to OFAC’s 50 percent rule . Date Updated: April 29, 2022 … the authorities listed above, and associated persons subject to sanctions pursuant to OFAC’s 50 percent rule . Date… Read more

558. Are news reporting organizations and journalists authorized to conduct activities in North Korea?

… and informational materials are exempt under the International Emergency Economic Powers Act, 50 U.S.C. § 1702(b) (IEEPA), these exemptions do not apply to transactions prohibited pursuant to … and informational materials are exempt under the International Emergency Economic… Read more

1096. Do U.S. sanctions prohibit U.S. persons from engaging in transactions that are ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation located in or outside the United States?

… 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 Gazprombank, or any entity in which Gazprombank owns, directly or… Read more

1054. Do the new investment prohibitions of Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”) prohibit U.S. persons from purchasing debt or equity securities issued by an entity in the Russian Federation?

… holdings of debt or equity securities issued by entities in the Russian Federation represent a 50 percent or more share by value of the fund. Generally, the fund may also divest itself of … holdings of debt or equity securities issued by entities in the Russian Federation… Read more

661. What does General License 9H authorize with respect to Petróleos de Venezuela, S.A. (PdVSA) debt and equity and what are the implications for U.S. and non-U.S. persons?

… to dealings in any debt of, or equity in, PdVSA, or any entity directly or indirectly owned 50 percent or more by PdVSA, that was issued prior to August 25, 2017 (together, "PdVSA … to dealings in any debt of, or equity in, PdVSA, or any entity directly or indirectly owned… Read more

821. What does General License No. 8A (GL 8A) authorize with respect to humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC)?

… transactions and activities involving the CBI, NIOC, or any entity in which NIOC owns a 50 percent or greater interest, that would be prohibited by the GTSR or by the ITSR as a result … transactions and activities involving the CBI, NIOC, or any entity in which NIOC owns a… Read more

42. What do I do if a person tries to open an account and the individual or entity’s name is on OFAC’s SDN List (or is otherwise a blocked person)? Do I open the account and then block the funds?

… who is otherwise blocked (e.g., a blocked government or an entity that is subject to the 50 Percent Rule). This is a prohibited service. However, the institution or its affiliates … who is otherwise blocked (e.g., a blocked government or an entity that is subject to the… Read more

644. Is an entity that is owned or controlled by a U.S. person and established or maintained outside the United States (a “U.S.-owned or -controlled foreign entity”) required to apply restrictions akin to blocking on the property or interests in property of persons subject to section 560.211 of the ITSR?

… ITSR deems an entity to be “owned or controlled” by a U.S. person if the U.S. person holds a 50 percent or greater equity interest by vote or value in the entity; holds a majority of seats … ITSR deems an entity to be “owned or controlled” by a U.S. person if the U.S. person… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence