Frequently Asked Questions

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

542. How does OFAC interpret the following terms as used in section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated into § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR): “significant transaction,” “significant financial transaction,” and “facilitated?”

… when determining whether transactions or financial transactions are “significant.” As a general matter, some or all of the following factors may be considered: (1) the size, number, … by § 589.209, a transaction is not significant if U.S. persons would not require a specific… Read more

463. Can nongovernmental organizations (NGOs) provide assistance to North Korea? If so, what types of assistance can NGOs provide? Can NGOs conduct transactions with the Government of North Korea?

… and customary taxes, fees, and import duties to, and purchase of receipt of permits, licenses, or public utility services from the Government of North Korea. In addition, for items … as EAR99 if located in the United States. For more information about OFAC and Commerce … Read more

164. The Iranian Transactions Regulations (ITR) authorize U.S. depository institutions and U.S. registered brokers or dealers in securities to process transfers of funds to or from Iran if the transfer is a non-commercial, personal remittance. Are U.S. depository institutions and U.S. registered brokers or dealers in securities still authorized to process such payments to or from a Government of Iran-owned bank that is not otherwise designated pursuant to another part of 31 C.F.R. Chapter V?

… General License B under E.O. 13599 authorizes U.S. depository institutions and U.S. registered … General License B under E.O. 13599 authorizes U.S. depository institutions and U.S. registered …

731. What type of cargo may a person authorized to provide carrier services transport from Cuba to the United States?

… States cargo, other than accompanied baggage, the importation of which has been authorized by general or specific license from OFAC, subject to obtaining any additional authorization(s) that may be required by … States cargo, other than accompanied baggage, the… Read more

1136. Can U.S. persons purchase bonds issued by the Government of Venezuela or Petróleos de Venezuela, S.A. (PdVSA) prior to August 25, 2017 on the secondary market?

… Yes. On October 18, 2023, OFAC issued amended General Licenses (GLs) 3I and 9H , to remove the restriction that any divestment by U.S. persons … Yes. On October 18, 2023, OFAC issued amended General Licenses (GLs) 3I and 9H , to remove the restriction that any… Read more

1039. Are transactions ordinarily incident and necessary to the exportation or reexportation of agricultural commodities to, from, or transiting the Russian Federation that involve Agropromyshlennyi Kompleks Voronezhskii OOO, Anninskii Elevator OOO, and Azovskaya Zernovaya Kompaniya OOO authorized under OFAC sanctions?

… operated in the financial services sector of the Russian Federation economy. Russia-related General License (GL) 6B authorizes, among other activities, certain transactions prohibited by … operated in the financial services sector of the Russian Federation economy. Russia-… Read more

514. If a U.S. person entered into a revolving credit facility or long-term loan arrangement for the Government of Venezuela prior to the sanctions effective date, what are the restrictions under E.O. 13808 on drawdowns from that facility? Do all drawdowns and disbursements pursuant to the parent agreement need to carry repayment terms of 90 days or less (for PdVSA) or 30 days or less (for the rest of the Government of Venezuela)?

… would constitute a prohibited transaction related to new debt under E.O. 13808 . Note that General License 2 authorizes all transactions in new debt of the Government of Venezuela of any … would constitute a prohibited transaction related to new debt under E.O. 13808 . Note that… Read more

855. How will transactions related to official activities of international organizations be treated for purposes of secondary sanctions to the extent that the Iranian financial sector or Iranian financial institutions sanctioned under Executive Order (E.O.) 13902 are involved?

… an Iranian financial institution (Iranian FI) blocked under E.O. 13902 are authorized under General License (GL) L to the extent they are authorized, exempt, or otherwise not prohibited by … E.O. 13902 that would be authorized for U.S. persons under GL L. In addition, Treasury… 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, any of the foregoing, including as a member of the Maduro regime. OFAC has issued several General Licenses (GLs) that provide authorization for categories of persons blocked by E.O. … see FAQ 679 regarding the scope of GL 31B . Without authorization from OFAC, U.S. persons… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence