Frequently Asked Questions

1008. Is there a wind-down period for the prohibitions imposed in Executive Order (E.O.) 14065?

… Yes. Through 12:01 a.m. eastern daylight time on March 23, 2022, Ukraine-related General License 17 authorizes transactions that are ordinarily incident and necessary to the wind … Yes. Through 12:01 a.m. eastern daylight time on March 23, 2022, Ukraine-related General… Read more

777. May persons subject to U.S. jurisdiction provide certain insurance-related services (such as cargo or hull insurance, or reinsurance) to persons subject to U.S. jurisdiction who are engaging in authorized activity in Cuba?

… the provision of insurance-related services is directly incident to activity authorized by general or specific license, then the provision of such services is authorized as well. For example, § 515.566 of the … transactions ordinarily incident to the exportation… Read more

1056. What does the June 9, 2022 amendment to the Cuban Assets Control Regulations (CACR) do?

… conferences in Cuba: Effective June 9, 2022, OFAC amended 31 CFR § 515.564(a) to include a general license authorizing, subject to conditions, travel-related and other transactions … Government of Cuba or prohibited member of the Cuban Communist Party. Finally, OFAC added a… Read more

1197. I'm a U.S. person with securities held at the National Settlement Depository (NSD), which were transferred pursuant to Russian Decree 840 to another Russian registrar. Am I required to block these securities?

… against Ukraine. Alongside this designation, OFAC issued, and subsequently extended, two general licenses (GLs) to allow for the wind down of certain transactions involving NSD, MOEX, … blocked persons, including certain local Russian registrars. This FAQ also noted that the… Read more

1184. What action did Treasury take on June 12, 2024 with regards to prohibiting certain information technology (IT) and software-related services?

… or the delivery of internet-based communications services. Treasury already has in place General License (GL) 25D , which authorizes certain transactions ordinarily incident and necessary to the … any country of any information or informational materials, regardless of format or… Read more

951. Is Afghanistan subject to comprehensive sanctions?

… Nationality Act. Transactions or activities by U.S. persons that involve these entities are generally prohibited. In addition, OFAC has issued GLs 14 , 15 , 16 , 17 , 18 , 19 , and 20 … 31 CFR part 597 (FTOSR), and E.O. 13224, as amended. For a consolidated list of all… Read more

980. Do non-U.S. persons risk being sanctioned for engaging in activity with persons sanctioned pursuant to Executive Order (E.O.) 14024?

… a blocked government. Please see sections 1(a)(vi) and 1(b) of E.O. 14024. Non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under E.O. 14024 for engaging in … subject to the prohibitions of the directives under E.O. 14024. Moreover, non-U.S. persons… Read more

1200. If a non-sanctioned person files a claim with their insurance company for a loss caused by a blocked person, such as a designated terrorist organization, is the insurance company permitted to pay the claim?

… the insurer against a blocked person. OFAC does not require U.S. persons to obtain a specific license to initiate legal proceedings against a blocked person. For example, a U.S. attorney, … Terrorist does not require a specific license. In most OFAC programs,… Read more

1239. Where can I find the account information to make authorized payments to the Foreign Government Deposit Funds deposit account, as specified in Executive Order 14373?

… for the Good of the American and Venezuelan People," and referenced in certain Venezuela General Licenses, depositors must first email the official point of contact for the deposit … Total payment amount, currency, and proposed payment date(s); Identification of the … Read more

554. For debt created on or after August 25, 2017, are U.S. persons permitted to accept payment from PdVSA or other segments of the Government of Venezuela if payment for a debt is not received within the applicable period specified in E.O. 13808 (90 days for PdVSA, 30 days for other segments of the Government of Venezuela)?

… No, absent a specific license or other authorization from OFAC. As explained in FAQ 553 , debt – which includes … of Venezuela. Because receiving payments outside of these specified maturity periods generally constitutes a prohibited dealing in debt, U.S. persons… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence