Frequently Asked Questions

850. How does the Treasury Department determine whether a transaction is “significant” for purposes of section 5(b) of the Hong Kong Autonomy Act (HKAA)?

… of the facts and circumstances when determining whether transactions are “significant.” As a general matter, the Treasury Department may consider some or all of the following factors in … a transaction will not be considered significant if a U.S. person would not require a… Read more

1166. What does the determination “Prohibitions Related to Imports of Diamond Jewelry and Unsorted Diamonds of Russian Federation Origin and Diamond Jewelry and Unsorted Diamonds Exported From the Russian Federation” pursuant to Executive Order (E.O.) 14068 (the “Diamond Jewelry and Unsorted Diamonds Determination”), prohibit?

… on the prohibition related to certain categories of non-industrial diamonds. Pursuant to General License (GL) 103 , U.S. persons are authorized to import into the United States diamond … on the prohibition related to certain categories of non-industrial diamonds. Pursuant to… Read more

1149. What sanctions can be imposed on a foreign financial institution (FFI) that engaged in conduct described in section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114? What are the obligations of U.S. financial institutions?

… account maintained for or on behalf of those foreign financial institutions. Russia-related General License (GL) 84 authorizes the closures of such accounts within 10 days of the imposition … account maintained for or on behalf of those foreign financial institutions. Russia-… Read more

1015. Is there a period for U.S. persons to continue imports prohibited by Executive Order (E.O.) of March 8, 2022, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine”?

… Through 12:01 eastern daylight time, April 22, 2022, Russia-related General License (GL) 16 authorizes all transactions prohibited by E.O. of March 8, 2022 that are … Through 12:01 eastern daylight time, April 22, 2022, Russia-related General License (GL) 16… Read more

1251. What does Executive Order (E.O.) 14404 of May 1, 2026, "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to U.S. National Security and Foreign Policy," do?

… prohibitions within and actions taken pursuant to E.O. 14404 do not affect the validity of licenses issued pursuant to the CACR. Additionally, on May 7, 2026, OFAC issued Cuba-related General License 1, "Transactions Authorized Pursuant to the Cuban Assets… Read more

163. What are the differences and similarities between E.O. 13599 and the Iranian Transactions Regulations (ITR)?

… for an Iranian financial institution. The transaction is not exempt or authorized by a general or specific license, and the Iranian bank is not blocked pursuant to the GTSR or the WMDPSR . Previously, … for an Iranian financial institution. The transaction is not… Read more

515. For purposes of Executive Order (E.O.) 13808 is the term "new equity" limited to equity that is issued by an entity owned or controlled by the Government of Venezuela after the sanctions effective date, or would equity purchased or acquired by an entity owned or controlled by the Government of Venezuela from a third party after the sanctions effective date be considered new equity?

… to transactions involving securities that fall into either of these two categories. General License 2 authorizes U.S. persons to deal in such new equity issued by CITGO Holding, … to transactions involving securities that fall into either of these two categories. General… Read more

1156. I have a shipment of a certain product(s) containing the types of seafood listed in the determination of December 22, 2023 pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114 of December 22, 2023, (Seafood Determination) en route to the United States that was contracted prior to December 22, 2023. Can I complete such import into the United States? Can I find a new buyer for this shipment and/or re-direct the shipment to a country other than the United States?

… types of seafood, for a limited time, into the United States subject to the conditions of General License (GL) 83 . GL 83 authorizes the importation into the United States, through 12:01 … types of seafood, for a limited time, into the United States subject to the conditions of… Read more

1028. Does the U.S. dollar-denominated banknote export ban imposed by Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” prohibit sending noncommercial, personal remittances denominated in U.S. dollars to the Russia Federation (or to individuals ordinarily resident in the Russia Federation)?

… Russian Federation or any person located in the Russian Federation. However, Russia-related General License (GL) 18 authorizes certain transactions that are ordinarily incident and … Russian Federation or any person located in the Russian Federation. However, Russia-related… Read more

1191. On September 12, 2024, OFAC designated Ly Yong Phat (Ly), L.Y.P. Group Co., LTD (L.Y.P. Group), and the following entities owned by L.Y.P. Group under the Global Magnitsky sanctions authority: O-Smach Resort, Garden City Hotel, Koh Kong Resort, and Phnom Penh Hotel. Can I continue to engage in transactions or other dealings with other entities owned by Ly or L.Y.P. Group that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

… are prohibited as a result of OFAC's designation, OFAC concurrently issued Global Magnitsky General License (GL) 8 authorizing U.S. persons to engage in all transactions with any entity … are prohibited as a result of OFAC's designation, OFAC concurrently issued Global… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence