Frequently Asked Questions

968. What foreign financial institutions are listed in Annex 1 to 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)?

… sector of the Russian Federation economy, or for being foreign financial institutions that are 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or … the Russia-related CAPTA Directive. Please see FAQ 969 regarding the applicability of… Read more

580. I am a foreign person that seeks to pay RUSAL or another entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest for goods or services connected with maintenance or wind-down activities authorized by General License 14. Am I required to deposit payment into a blocked account at a U.S. financial institution in order for my payment to not 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 RUSAL (or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest) without making associated payments into a blocked account. … that seeks to pay RUSAL or another entity in which RUSAL owns, directly or indirectly, a… Read more

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

1248. Since January 2026, OFAC has issued a series of Venezuela-related General Licenses related to purchases and investment in Venezuela's natural resource sectors, such as Venezuela-related General Licenses (GLs) 48A and 50A, that include a reporting requirement. Which parties are responsible for providing such reports pursuant to those General Licenses?

In general, the parties engaged in the primary authorized activity are responsible for complying with the applicable reporting requirements in these Venezuela-related GLs. Parties that are only indirectly involved or providing services ancillary to the primary authorized activity are not required… Read more

656. Can U.S. persons in Venezuela purchase gasoline or other refined petroleum products from Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest?

… or humanitarian uses from PdVSA, or any entity in which it owns, directly or indirectly, a 50 percent or greater interest. General License 10 authorizes, among other things, purchases of … Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly… 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

1258. I am a non-U.S. person, what is my exposure to sanctions risk for transacting with entities owned by Grupo de Administración Empresarial S.A. (GAESA), the Cuban Ministry of the Interior (MININT), or the Cuban Ministry of the Revolutionary Armed Forces (MINFAR), including their subsidiaries listed on the Cuba Restricted List (CRL)?

… transactions with any entity in which GAESA, MININT, or MINFAR own, directly or indirectly, a 50 percent or greater interest. Many of the entities listed on the CRL are 50 percent or more owned by one of these three entities and therefore present the same… 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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence