Frequently Asked Questions

758. Is Cuba open for U.S. business and investment?

… are prohibited from doing business or investing in Cuba unless authorized by OFAC. An OFAC general license authorizes, subject to certain conditions and limitations, the exportation from … reexportation from third countries, of items to Cuba where the exportation or reexportation… Read more

828. I want to help with the humanitarian response to public health concerns, including the Coronavirus Disease 2019 (COVID-19) outbreak, in Iran. What can I do to help while remaining compliant with U.S. sanctions?

… by U.S. persons, including the donation of medicine intended to relieve human suffering, are generally exempt from U.S. sanctions on Iran under section 560.210(b) of the Iranian Transactions … Designated Global Terrorist pursuant to Executive Order (E.O.) 13224 as amended, please… Read more

808. Do I need a specific license from OFAC to file a suit in U.S. court against a person designated or blocked pursuant to Venezuela-related sanctions? Does a U.S. court, or its personnel, need a specific license from OFAC to hear such a case?

… No. A specific license from OFAC is not required to initiate or continue U.S. legal proceedings against a person … OFAC authorization for matters involving property blocked under the VSR. However, a specific license from OFAC is required for the entry into a… Read more

778. Does a person subject to U.S. jurisdiction require an OFAC specific license to pay an insurance claim that arises from authorized activity in Cuba if the payment involves a Cuban national?

… Where the provision of insurance-related services is authorized by general license, either expressly or as a transaction ordinarily incident to a licensed transaction, this authorization extends to the payment or settlement of claims, … Does a person subject to U… Read more

1100. I am a U.S. person that owns debt or equity, including publicly traded shares, in Pingtan Marine Enterprise, Ltd. (PME), which was designated under Executive Order (E.O.) 13818. What actions am I authorized to take under Global Magnitsky General License 3?

… Pursuant to Global Magnitsky General License (GL) 3 , U.S. persons are authorized to engage in certain transactions that would … Executive Order (E.O.) 13818. What actions am I authorized to take under Global Magnitsky General License 3? … Pursuant to Global… Read more

734. What is the Cuba Restricted List and how does it impact Cuba-related transactions?

… and exceptions that apply, see 31 CFR § 515.209 . This prohibition applies to the following general licenses: §§ 515.530, 515.534, 515.545, 515.560, 515.561,515.564, 515.565, 515.566, … 515.577, 515.578, 515.581,515.584, and 515.590. For a complete description of what each… Read more

117. Specific to Iran I hold a specific license to sell agricultural goods, medicine, or medical devices to Iran. The general license at section 560.532(a)(4) of the Iranian Transactions and Sanctions Regulations (ITSR) authorizes me to accept a letter of credit issued by an Iranian financial institution whose property and interests in property are blocked solely pursuant to the ITSR (i.e., an Iranian financial institution that is not listed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List)). The general license, however, also states that a U.S. financial institution may not advise, confirm, or otherwise deal in that credit. How am I supposed to know if/when a letter of credit has been issued for my sale and how do I get paid? My bank accounts are all at U.S. financial institutions.

… This language is in the general license at section 560.532(a)(4) of the ITSR because it is contrary to U.S. foreign policy to … or a U.S.-owned or -controlled foreign entity from receiving funds in payment for the licensed export from a third-country bank. You… Read more

580. I am a foreign person that seeks to pay RUSAL or another entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest for goods or services connected with maintenance or wind-down activities authorized by General License 14. Am I required to deposit payment into a blocked account at a U.S. financial institution in order for my payment to not be considered “significant” for purposes of section 10 of SSIDES, as amended by section 228 of CAATSA, or section 5 of UFSA, as amended by section 226 of CAATSA?

… No. U.S. persons may engage in activities authorized by General License 14 that occur on or after April 23, 2018, except for activities involving blocked … account. Similarly, foreign persons may engage in activities that would be authorized by General License 14… Read more

521. I want to provide long-term financing to the Government of Venezuela to help with the exportation or reexportation of agricultural commodities, medicine, medical devices, components, or replacement parts and components for medical devices to Venezuela. Is that allowed?

… Yes. General License 4 authorizes all financing and other dealings in new debt related to the … specifically for resale to Venezuela, provided that the exportation or reexportation is licensed or otherwise authorized by the Department of Commerce. Note, however,… Read more

780. Are there any exceptions to the 180-day rule and the goods/passengers-on-board rule?

… Yes. OFAC has authorized by general license certain exceptions to these rules. If a vessel engages only in one or more of the … authorized under the CACR, such as a vessel carrying goods from the United States that are licensed or otherwise authorized for export… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence