Frequently Asked Questions

847. As a result of the sanctions on the Iranian financial sector and certain Iranian financial institutions (Iranian FIs) pursuant to Executive Order (E.O.) 13902, do non-U.S. persons risk exposure to sanctions for continuing to engage in previously non-sanctionable trade involving the Iranian financial sector or E.O. 13902-sanctioned Iranian FIs, even after the end of the 45-day wind-down period?

… For purposes of E.O. 13902, OFAC would not generally view transactions or activities by non-U.S. persons to be sanctionable if they are … with activities that would be permissible if conducted by U.S. persons. As noted in FAQ 842 , General License (GL) L… Read more

545. What do the following key terms in section 10 of the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES), as amended by section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), mean: “foreign person,” “knowingly,” “materially violate,” “facilitates . . . for or on behalf of,” “significant transaction,” and “deceptive or structured transaction”?

… about whether a violation is egregious will be based on an analysis of the applicable General Factors as described in OFAC’s Economic Sanctions Enforcement Guidelines, located in … from which the person in question derives a particular benefit of any kind (as opposed to a… Read more

1088. What are OFAC’s due diligence expectations for cloud-based service or software providers whose services and software support communication tools are authorized by 31 CFR § 560.540?

… exportation of services or software to Iran authorized under 31 CFR § 560.540, OFAC does not generally expect a cloud-based service or software provider to evaluate the ultimate end use or … a prohibited export of software or services to Iran because payroll management software… Read more

1080. I am a U.S. person with an account at a Russian financial institution blocked pursuant to Executive Order (E.O.) 14024. What am I required or allowed to do under OFAC sanctions with respect to such accounts?

… this means that accounts held by U.S. persons at any blocked Russian financial institutions generally are themselves considered blocked property, unless exempt. This includes, for example, … blocked property as of June 30 of this year. On August 19, 2022, OFAC issued Russia-… Read more

1135. How can companies participate in the humanitarian channel in Qatar to export humanitarian goods to Iran?

… involving the Central Bank of Iran and the National Iranian Oil Company are permissible under General License 8A ( see also FAQ 823 ). OFAC FAQ 828 and our Guidance on the Sale of Food, … involving the Central Bank of Iran and the National Iranian Oil Company are permissible… Read more

1096. Do U.S. sanctions prohibit U.S. persons from engaging in transactions that are ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation located in or outside the United States?

… OFAC issued Russia-related General License (GL) 53A to authorize U.S. persons to engage in all transactions ordinarily … OFAC issued Russia-related General License (GL) 53A to authorize U.S. persons to engage in all transactions ordinarily …

1071. Can I wind down financial contracts that may involve transactions prohibited pursuant to section (1)(a)(i) of Executive Order (E.O.) 14071 related to the purchase or receipt of debt or equity securities issued by an entity in the Russian Federation?

… Through 12:01 a.m. eastern daylight time, October 20, 2022, Russia-related General License (GL) 45 (this content is no longer available) authorizes all transactions … Through 12:01 a.m. eastern daylight time, October 20, 2022, Russia-related General License (GL)… Read more

960. Can nongovernmental organizations (NGOs) and international organizations (IOs) make salary support or stipend payments directly to Afghan teachers and healthcare workers?

… workers, such as doctors at public hospitals or healthcare workers at community clinics, under General License (GL) 14 and GL 19 . Similarly, even to the extent doing so would involve … workers, such as doctors at public hospitals or healthcare workers at community clinics,… Read more

961. Can nongovernmental organizations (NGOs) and international organizations (IOs) provide support to municipal water systems?

… amended, because of transactions with the Taliban and/or Haqqani Network would be covered by General Licenses (GLs) 14 and 19 . GL 18 authorizes all transactions and activities with the … amended, because of transactions with the Taliban and/or Haqqani Network would be covered by… Read more

979. I am a U.S. person. Can I rely on a person sanctioned pursuant to Executive Order (E.O.) 14024 in connection with transactions for official business of an international organization, certain humanitarian-related trade, or the response to the Coronavirus Disease 2019 (COVID-19) pandemic?

… are exempt from the sanctions prohibitions of E.O. 14024. Additionally, OFAC has issued General License (GL) 5 , authorizing transactions for the conduct of the official business of … are exempt from the sanctions prohibitions of E.O. 14024. Additionally, OFAC has issued … Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence