Frequently Asked Questions

160. Section 1 of E.O. 13599 blocks all property and interests in property of the Government of Iran, including the Central Bank of Iran, and of all Iranian financial institutions, that are in the United States, that come within the United States, or that come within the possession or control of U.S. persons (including overseas branches). Can you provide further clarification about this provision of E.O. 13599?

… in property of that entity are blocked if the entity is owned, directly or indirectly, 50% or more by a person whose property and interests in property are blocked pursuant to an … in property of that entity are blocked if the entity is owned, directly or indirectly, 50… Read more

508. What do the prohibitions in Executive Order (E.O) .13808 mean? Are they blocking actions?

… the Government of Venezuela and any entity in which it owns, directly or indirectly, a 50 percent or greater interest, U.S. persons are prohibited from engaging in any activity or … the Government of Venezuela and any entity in which it owns, directly or indirectly, a 50… Read more

984. What does 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?

… relevant sanctions effective date. Please see FAQ 985 regarding the applicability of OFAC's 50 Percent Rule with respect to this directive. Entity Type Relevant Sanctions Effective Date … relevant sanctions effective date. Please see FAQ 985 regarding the applicability of… Read more

835. What does Global Magnitsky General License 2A authorize?

… down of transactions involving any entity in which the XPCC owns, directly or indirectly, a 50 percent or greater interest (Blocked XPCC Subsidiary), through 12:01 a.m. eastern standard … down of transactions involving any entity in which the XPCC owns, directly or indirectly, a… Read more

929. For the purposes of Afghanistan-related General License (GL) 14, what is "humanitarian assistance to Afghanistan" or "other activities that support basic human needs in Afghanistan"?

… or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest, other than for the purpose of effecting the payment of taxes, … or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a… 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?

… Joint Stock Company Sberbank of Russia; VTB Bank Public Joint Stock Company; Any entity owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one of the above … Joint Stock Company Sberbank of Russia; VTB Bank Public Joint Stock Company; Any… Read more

975. Is there a wind-down period for transactions involving the Russian financial institutions blocked in February 2022 pursuant to Executive Order (E.O.) 14024? What transactions are authorized during the wind-down period?

… these financial institutions own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. GLs 3 and 11 authorize U.S. persons to engage in transactions … these financial institutions own, directly or indirectly, individually or in the… Read more

974. What Russian financial institutions were blocked in February 2022 pursuant to Executive Order (E.O.) 14024, and what activities are prohibited as a result?

… of any entity that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Accordingly, U.S. persons, … of any entity that is owned, directly or indirectly, individually or in the aggregate, … Read more

511. For purposes of Executive Order (E.O.) 13808, what does OFAC interpret to be debt and equity? Can U.S. financial institutions continue to maintain correspondent accounts and process U.S. dollar-clearing transactions for the entities subject to these sanctions?

… of Venezuela of any equity interest in any entity in which the Government of Venezuela has a 50 percent or greater ownership interest; and any dealing in, including provision of services in … of Venezuela of any equity interest in any entity in which the Government of Venezuela… Read more

967. What does Directive 2 under Executive Order (E.O.) 14024, "Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions" (Russia-related CAPTA Directive) prohibit?

… for purposes of this directive. Please see FAQ 969 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive. Annex 1 to the Russia-related CAPTA Directive … for purposes of this directive. Please see FAQ 969 regarding the applicability of OFAC’s… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence