Frequently Asked Questions

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

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

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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence