Frequently Asked Questions

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

104. Can an insurer offer global travel insurance and worldwide travel assistance without violating U.S. sanctions?

… directly or indirectly, transactions ordinarily incident to travel to or from any country. See 50 U.S.C. §1702 (b)(4). OFAC sanctions programs issued pursuant to IEEPA generally do not … directly or indirectly, transactions ordinarily incident to travel to or from any country.… 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

1006. What does Executive Order (E.O.) 14065 do?

… are generally prohibited from engaging in transactions with them. Additionally, any entities 50 percent or more owned, directly or indirectly, by one or more blocked persons are also … are generally prohibited from engaging in transactions with them. Additionally, any entities… Read more

1259. Are private and commercial flights authorized to arrive in and depart from airports in Venezuela, and can they receive ground services in-country?

… on OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List) or owned 50 percent or more by persons identified on the SDN List. Generally, non-U.S. persons do not risk … on OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List)… Read more

966. What actions did Treasury take in February 2022 related to Russia's financial services sector pursuant to Executive Order (E.O.) 14024?

… Public Joint Stock Company Sberbank of Russia and other foreign financial institutions owned 50 percent or more by this bank as subject to these prohibitions, which become effective on March … of any entity that is owned, directly or indirectly, individually or in the aggregate… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence