Frequently Asked Questions

970. Are foreign financial institutions (FFIs) located outside of Russia potentially subject to the prohibitions of Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?

… Russia-related CAPTA Directive, or their property or interests in property—which includes FFIs 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or … the Russia-related CAPTA Directive. This includes, for example, banking subsidiaries… Read more

654. With regard to Venezuela-related General License 11, “Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with Petróleos de Venezuela, S.A.,” are U.S. financial institutions required to reject funds transfers involving both Petróleos de Venezuela, S.A. (PdVSA) or entities owned, directly or indirectly, 50 percent or more by PdVSA, and a non-U.S. entity located in a country other than the United States or Venezuela?

… contracts, or other agreements involving PdVSA or entities owned, directly or indirectly, 50 percent or more by PdVSA that were in effect prior to January 28, 2019. The authorization is … block, funds transfers that involve both PdVSA or any entity owned, directly or indirectly… Read more

575. Why is OFAC issuing General License 14, and what new activity does it authorize?

… Company RUSAL PLC (RUSAL) or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest, to continue maintenance or wind down activities until October 23, … persons other than RUSAL or any other entity in which RUSAL owns, directly or… Read more

590. I am a foreign person that seeks to pay GAZ Group or another entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest for goods or services connected with activities authorized by General License (GL) 15L. Am I required to deposit payment into a blocked account at a U.S. financial institution in order for my payment not to be considered “significant” for purposes of section 10 of SSIDES, as amended by section 228 of CAATSA, or section 5 of UFSA, as amended by section 226 of CAATSA?

… persons other than GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) without making associated payments into a blocked account. … seeks to pay GAZ Group or another entity in which GAZ Group owns, directly or indirectly, a… Read more

591. I am a U.S. person that seeks to supply goods to GAZ Group. Am I permitted to export those goods from the United States to GAZ Group pursuant to General License (GL) 15L?

… involving GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest), including exports. Any exports to GAZ Group must be consistent … exports) involving GAZ Group, or any entity in which GAZ Group owns, directly or indirectly, a… Read more

1129. Do blocking sanctions issued by the State Department on May 19, 2023 on Polimetall AO apply to its corporate parent and affiliates?

… apply only to this entity and any entities in which it owns, directly or indirectly, a 50 percent or greater interest. Neither the Department of State nor OFAC have designated this … PLC, and based on information available to OFAC, Polymetal International PLC is not owned… Read more

982. Are U.S. funds allowed to buy or sell debt or equity of blocked Russian financial institutions? Are U.S. investors allowed to invest in a fund that holds debt or equity of a blocked Russian financial institution?

… generally is not itself considered a blocked entity unless such blocked holdings represent a 50 percent or more share by value of the fund. If such blocked holdings do not represent a 50 percent or more share by value of the fund, U.S. persons may continue to… Read more

569. A U.S. company had ordered goods from an entity that was designated under E.O. 13661 or E.O. 13662, or blocked pursuant to OFAC’s 50 percent rule on April 6, 2018 as a result of such a designation. May the U.S. company still accept the goods?

… an entity that was designated under E.O. 13661 or E.O. 13662, or blocked pursuant to OFAC’s 50 percent rule on April 6, 2018 as a result of such a designation. May the U.S. company still … an entity that was designated under E.O. 13661 or E.O. 13662, or blocked pursuant to OFAC’s… Read more

1104. Is Norilsk Nickel blocked as a result of the designation of Vladimir Potanin?

… based on information available to OFAC as of December 15, 2022, Norilsk Nickel is not owned 50% or more by blocked persons or otherwise considered the blocked property of Vladimir Potanin. … based on information available to OFAC as of December 15, 2022, Norilsk Nickel is not… Read more

570. I own shares in or global depositary receipts (GDRs) related to shares in an entity that was designated under E.O. 13661 or E.O. 13662, or blocked pursuant to OFAC’s 50 percent rule on April 6, 2018 as a result of such a designation. What action am I allowed to take with respect to those shares or GDRs?

… other holdings in GAZ Group, or in entities in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, that were issued by GAZ Auto Plant (“Other Issuer Holdings”), … activities involving GAZ Group, or entities in which GAZ Group owns, directly or… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence