Frequently Asked Questions

1196. What should I do if I blocked and reported property in error due to mistaken identity or typographical or similar errors?

… due to mistaken identity or typographical errors, rather than an OFAC authorization like a general or specific license. Please note, unblocking property in which a blocked person does in fact have an … ownership by a blocked person). In such scenarios,… Read more

771. May a person subject to U.S. jurisdiction provide training to a Cuban distributor or customer on the use of goods authorized for export to Cuba by the Department of Commerce?

… to travel to Cuba to provide such training. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.533 (c)(1). Please … to travel to Cuba to provide such training. For a complete description of what this … Read more

779. What are the “180-day rule” and the “goods/passengers-on-board rule”?

… For a complete description of the 180-day rule, the goods/passengers-on-board rule, and the general licenses and exemptions that apply, see 31 CFR §§ 515.206, 515.207, and 515.550. … For a complete description of the 180-day rule, the goods/passengers-on-board rule, and the… 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?

… August 25, 2017, and, in the case of bonds, either (1) the bonds are included in the Annex to General License 3, or (2) the bonds were issued by U.S. person entities owned or controlled, … or indirectly, by the Government of Venezuela (such as CITGO Holding, Inc.). The Annex to… Read more

635. Can I, as a U.S. person or U.S.-owned or -controlled foreign entity, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period under an OFAC wind-down authorization and pursuant to a contract entered into prior to May 8, 2018?

… would require specific authorization from OFAC. OFAC will evaluate such requests for specific licenses on a case-by-case basis. Any request for a specific license should provide sufficient details for OFAC to evaluate the application, including: … for which… Read more

928. Do U.S. sanctions on the Taliban and the Haqqani Network prohibit the provision of humanitarian assistance to Afghanistan?

… exempt from regulation or authorized by OFAC. In addition, OFAC has issued Afghanistan-related General Licenses (GLs) 14 , 15 , 16 , 17 , 18 , 19 , and 20 under the Global Terrorism Sanctions … and Evaluation Division most efficiently via the OFAC Compliance hotline . OFAC… Read more

1220. How does Executive Order (E.O.) 14312, "Providing for the Revocation of Syria Sanctions," affect OFAC’s Syria Sanctions Program?

… as a Specially Designated Global Terrorist organization from the SDN List. As a result, General License (GL) 25, which authorized certain transactions that could otherwise have been … to the role of HTS in the Syrian government, is no longer necessary, and OFAC has revoked the… Read more

817. What is the significance of OFAC’s designations of Rosneft Trading S.A. and TNK Trading International S.A.? Do the E.O. 13850 blocking sanctions on Rosneft Trading S.A. and TNK Trading International S.A. apply to their corporate parent and their affiliates?

… S.A. pursuant to E.O. 13850 for operating in the oil sector of the Venezuelan economy. General License 36A authorizes U.S. persons to engage in certain activities prohibited by E.O. … ensure that all activities comply with any applicable Directive 2 and 4 prohibitions, because… Read more

1145. What if a governing institution in Afghanistan is led by an individual who has been blocked pursuant to the Global Magnitsky Sanctions Regulations?

… Generally, the designation of an individual with a leadership role in a governing institution … transactions involving individuals blocked pursuant to the GMSR may be authorized by general licenses (GL) in the GMSR related to certain international organizations (… Read more

744. May correspondent accounts authorized pursuant to 31 CFR § 515.584(a) or used for transactions authorized by 31 CFR § 515.584(g) be established and maintained in U.S. dollars?

… accounts at a U.S. financial institution. For a complete description of what these general licenses authorize and the restrictions that apply, see 31 CFR § 515.584(a) and (g). … accounts at a U.S. financial institution. For a complete description of what these general… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence