Frequently Asked Questions

579. Will foreign persons be subject to sanctions under CAATSA for engaging in activity with RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest?

… in activity with RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest? … in activity with RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest? …

985. Does the 50 Percent Rule apply to Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive)?

… Entities Directive, or their property or interests in property, which includes entities 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or … Does the 50 Percent Rule apply to Directive 3 under Executive Order (E.O.)… Read more

1243. What authorizations exist to develop oil or gas projects in Venezuela for companies that are not listed in Venezuela General License (GL) 50A (Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities)?

Entities not identified in the Annex to GL 50A can rely on other authorizations to support the development of oil or gas projects in Venezuela. For example, such companies can enter into contingent contracts for new investments in the Venezuela oil or gas sectors pursuant to GL 49 and submit a… Read more

651. What happened to the Petróleos de Venezuela, S.A. (PdVSA) bonds, or bonds issued by any entity directly or indirectly owned 50 percent or more by PdVSA, that were previously included in the Annex to General License 3?

… Bonds issued by PdVSA or any entity in which it owns, directly or indirectly, a 50 percent or greater interest that was previously listed in the Annex to General License 3 (this … de Venezuela, S.A. (PdVSA) bonds, or bonds issued by any entity directly or indirectly owned… Read more

680. Does the blocking of the Government of Venezuela impact the ability of U.S. persons to transact with the Government of Venezuela, or persons in which the Government of Venezuela owns, directly or indirectly, a 50 percent or greater interest?

… of Venezuela, or persons in which the Government of Venezuela owns, directly or indirectly, a 50 percent or greater interest. U.S. persons are not prohibited from engaging in transactions … the definition of Government of Venezuela and persons that are owned, directly or… Read more

576. Under what circumstances can OFAC give further sanctions relief to RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest?

… sanctions relief to RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest? … sanctions relief to RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest? …

658. Can U.S. persons purchase, or engage in other transactions including swaps and non-cash transactions involving the purchase or exchange of, petroleum and petroleum products, if Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest is not directly involved in the transaction?

… or petroleum products in which PdVSA or any entity in which it owns, directly or indirectly, a 50 percent or greater interest has a direct or indirect interest will be prohibited for U.S. … or non-cash agreement owed to PdVSA or any entity in which it owns, directly or indirectly… Read more

586. What transactions are authorized under wind-down General License (GL) 15L?

… involving GAZ Group, or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, and that were in effect prior to April 6, 2018, GL 15L only … involving GAZ Group and any entity in which GAZ Group owns, directly or indirectly, a 50… Read more

969. Does OFAC’s 50 Percent Rule apply to foreign financial institutions listed in Annex 1 to 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)?

… “or their property or interests in property,” which includes foreign financial institutions 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or … non-“foreign financial institutions,” even if those non-“foreign financial institutions” are… Read more

822. I'm a U.S. person that relied on general or specific licenses pursuant to 560.530, 560.532, or 560.533 of the ITSR to conduct humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) prior to their designations under E.O. 13224, as amended. Is any further authorization needed to conduct such transactions following the designations of the CBI and NIOC under E.O. 13224?

… 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 due to the … such transactions and activities involving the CBI, NIOC, or any entity in which NIOC owns a… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence