Frequently Asked Questions

654. With regard to Venezuela-related General License 11, “Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with Petróleos de Venezuela, S.A.,” are U.S. financial institutions required to reject funds transfers involving both Petróleos de Venezuela, S.A. (PdVSA) or entities owned, directly or indirectly, 50 percent or more by PdVSA, and a non-U.S. entity located in a country other than the United States or Venezuela?

… General License 11 authorizes, with certain exceptions, U.S. person employees of non-U.S. … 12:01 a.m. eastern daylight time on March 29, 2019. In accordance with paragraph (b) of General License 11, and for purposes of activities authorized under General… Read more

783. May companies that use different ocean carriers as part of a broader shipping service utilizing code-sharing agreements take advantage of the exceptions to the “180-day rule”?

… to the 180-day rule apply to each individual vessel that meets the requirements of the general license irrespective of any code-sharing arrangement. Thus, any shipping company may … a vessel in a broader shipping arrangement and, so long as the vessel meets the terms of the… Read more

656. Can U.S. persons in Venezuela purchase gasoline or other refined petroleum products from Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest?

… Yes. Venezuela-related General License 10 authorizes U.S. persons in Venezuela to purchase refined petroleum products, … or any entity in which it owns, directly or indirectly, a 50 percent or greater interest. General License 10 authorizes, among other things,… Read more

1017. Does Russia-related General License (GL) 8L remain valid following the issuance of Executive Order (E.O.) 14066, "Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine"?

… Does Russia-related General License (GL) 8L remain valid following the issuance of Executive Order (E.O.) 14066, … Does Russia-related General License (GL) 8L remain valid following the issuance of Executive Order (E.O.) 14066, …

1107. For purposes of the OFAC general licenses related to the official business of certain international organizations and entities (IO GLs), what organizations are included within the United Nations' "Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations"?

… For purposes of the OFAC general licenses related to the official business of certain international organizations and … For purposes of the OFAC general licenses related to the official business of certain international organizations and …

1182. Are foreign financial institutions (FFIs) subject to sanctions risk for providing all financial services involving persons blocked pursuant to Executive Order (E.O.) 14024, as amended? What about agricultural, medical, and other transactions authorized by OFAC General Licenses?

… the imposition of sanctions for engaging in transactions authorized for U.S. persons under General Licenses issued under the Russian Harmful Foreign Activities Sanctions program. FFIs may … and related replacement parts, components, or software updates, the Coronavirus Disease… Read more

453. Pursuant to General License 6 under the Ukraine-Related Sanctions Program, are U.S. financial institutions authorized to process noncommercial, personal remittances to or from Crimea (or to or from individuals ordinarily resident in Crimea) when there is no individual who is a U.S. person as either the remitter or beneficiary in the transaction?

… money transmitters are authorized to process noncommercial, personal remittances pursuant to General License 6 regardless of whether the originator or beneficiary is an individual who is a U.S. person. For example, General License 6 authorizes a U.S. depository… Read more

747. May U.S. banks, their foreign branches, and foreign subsidiaries open and operate accounts for Cuban nationals in third countries?

… Section 515.585 of the CACR contains a general license that authorizes all persons subject to U.S. jurisdiction to provide goods and … the transaction does not involve commercial exportation to or from Cuba. Additionally, the general license authorizes banking… Read more

362. Is the exportation or reexportation of non-U.S.-origin agricultural commodities, medicine, or medical devices by a U.S. person to Iran authorized?

… of the terms “agricultural commodities,” “medicine,” and “medical device” used in the relevant general licenses in the ITSR include, in the case of items subject to Commerce's Export … if they were located in the United States. For example, under the agricultural commodities… Read more

1106. Are financial institutions permitted to provide banking services, including processing funds transfers, related to activities authorized under the four categories of the general licenses (GLs) outlined in FAQ 1105? What are OFAC's diligence expectations of financial institutions seeking to engage in such activities?

… that are otherwise exempt or authorized for U.S. persons pursuant to these GLs. For general information on OFAC's due diligence expectations and compliance programs, please see A … processing funds transfers, related to activities authorized under the four categories of the… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence