Frequently Asked Questions

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

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

1073. Is Sheremetyevo International Airport blocked as a result of the designation of Alexander Anatolevich Ponomarenko?

… and, based on information available to OFAC, Sheremetyevo International Airport is not owned 50% or more by blocked persons or otherwise considered the blocked property of Alexander … and, based on information available to OFAC, Sheremetyevo International Airport is not owned… 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

1001. Does the 50 Percent Rule apply to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)?

… Does the 50 Percent Rule apply to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to … Does the 50 Percent Rule apply to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to …

804. Do sanctions on COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. apply to its corporate parent and affiliates?

… apply only to this listed entity and any entities in which it owns, directly or indirectly, a 50 percent or greater interest. Sanctions do not apply to this entity’s ultimate parent, COSCO … or affiliates (e.g., COSCO Shipping Holdings), provided that such entities are not owned… Read more

1190. Do U.S. sanctions target persons for engaging in political speech, religious practice, or other constitutionally protected activities?

… programs are promulgated pursuant to the International Emergency Economic Powers Act , 50 U.S.C. 1701 et seq. , which limits the authority to “regulate or prohibit, directly or … whether commercial or otherwise, . . . of any information or informational materials.” 50… Read more

1032. On April 20, 2022, Transkapitalbank (TKB) was designated pursuant to Russia-related Executive Order 14024. Can U.S. persons continue to engage in Afghanistan-related transactions with TKB?

… certain transactions involving TKB, or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, that are ultimately destined for or originating from Afghanistan … accounts on behalf of TKB, or any entity in which TKB owns, directly or indirectly, a… Read more

1262. On July 13, 2026, the Department of State designated the Cuban entities Grupo Empresarial del Comercio Exterior (GECOMEX) and Grupo Empresarial de Transporte Marítimo Portuario (GEMAR) pursuant to E.O. 14404. Are non-U.S. persons, including foreign financial institutions (FFIs), exposed to sanctions risk for winding down transactions with GECOMEX or GEMAR?

… GECOMEX, GEMAR, or any entity in which either GECOMEX or GEMAR owns, directly or indirectly, a 50 percent or greater interest, through August 12, 2026. However, non-U.S. persons, including … GECOMEX, GEMAR, or any entity in which either GECOMEX or GEMAR owns, directly or… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence