Frequently Asked Questions

1087. Does the general license at 31 CFR § 560.540 authorize the exportation of fee-based or no-cost cloud-based services and software to Iran that are used to support communications tools authorized by 31 CFR § 560.540?

… and services pursuant to 31 CFR § 560.530, and transactions authorized pursuant to any general or specific licenses issued under the ITSR. Please note that 31 CFR § 560.540(a)(1) does not authorize the … Does the general license at 31 CFR § 560.… Read more

981. What does General License (GL) 9A authorize with respect to the debt and equity of certain Russian financial institutions sanctioned pursuant to Executive Order (E.O.) 14024? What are the implications for U.S. and non-U.S. persons?

… General License (GL) 9A authorizes U.S. persons, until 12:01 a.m. eastern daylight time May 25, 2022, to … daylight time on May 25, 2022. After May 25, 2022, U.S. persons would require a specific license to continue to receive such payments. Certain… Read more

1224. What negotiations does Russia-related General License 131I authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?

… To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131I , which authorizes negotiations and entry into contingent contracts with Lukoil … value to Lukoil, including through asset or share swaps. Further, as a… Read more

523. The Venezuela Government International Bond issued on December 29, 2016 (ISIN USP97475AQ39, CUSIP AM1108092) is not included in the Annex to General License 3. Is that intentional? Did OFAC intentionally exclude any other bonds from the Annex?

… on December 29, 2016 (ISIN USP97475AQ39, CUSIP AM1108092) (“the 2036 bond”) from the Annex to General License 3 because available information indicates that the Government of Venezuela is … the 2036 bond is the only bond we have identified and purposely omitted from the Annex to… Read more

58. Is OFAC likely to approve my license application? How long will it take?

… OFAC reviews each specific license application on a case-by-case basis, generally in the order in which they are received. The review process for each license … to consult with other U.S. government agencies. Additionally, an increase in the… Read more

363. Is the exportation or reexportation by non-U.S. persons of agricultural commodities, medicine, or medical devices that are subject to the Export Administration Regulations (EAR) to Iran authorized?

… or reexport agricultural commodities, medicine, or medical devices to Iran under the relevant general licenses in the ITSR , provided that the items are subject to Commerce's Export Administration Regulations (EAR); and all conditions of the relevant general license… Read more

843. I'm a U.S. person that relied on general or specific licenses issued pursuant to the Iranian Transactions and Sanctions Regulations (ITSR) to conduct humanitarian-related or other transactions and activities prior to the identification of the financial sector of Iran and sanctioning of a number of Iranian financial institutions (Iranian FIs) under E.O. 13902. Is any further authorization needed to conduct such transactions following these actions?

… No. General License (GL) L extends authorizations provided through specific and general licenses issued under … I'm a U.S. person that relied on general or specific licenses issued pursuant to the Iranian Transactions and… Read more

577. I am a U.S. person holding accounts for or other property of RUSAL or another entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest. Does General License 14 allow me to unblock this property?

… 2018 remain blocked, except for the use in maintenance and wind-down activities described in General License 14. U.S. persons, however, may engage in transactions authorized by General License 14 that occur on or after April 23, 2018 without blocking payments… Read more

1215. Why did OFAC issue General License (GL) 26 ("Transactions Authorized Pursuant to the Russian Harmful Foreign Activities Sanctions Regulations") in the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589 (URSR)?

… that transactions authorized or exempt under the RuHSR, including transactions authorized by a general or specific license, that involve those specified persons are also authorized under the URSR, to the extent … Why did OFAC issue General… Read more

978. For transactions authorized under Russia-related General Licenses (GL) 6D, 7A, 115D, or 132, what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024?

… For transactions authorized under Russia-related General Licenses (GL) 6D, 7A, 115D, or 132, what is an example of a permissible funds transfer … For transactions authorized under Russia-related General Licenses (GL) 6D, 7A, 115D, or 132, what is an example of a… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence