Frequently Asked Questions

659. Does Venezuela-related General License 12 authorize U.S. persons to export goods, services, and technology from the United States to Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest during the wind-down period?

659 … General License 12 authorizes, until 12:01 a.m. eastern standard time, February 27, 2019, all transactions and activities that are ordinarily incident and necessary to the wind down of operations, contracts, or other agreements that were in effect prior to January 28, 2019. This… Read more

660. When will sanctions be lifted on Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest?

660 … The path to sanctions relief for PdVSA and its subsidiaries is through the expeditious transfer of control of the company to a democratically elected government that is committed to taking concrete and meaningful actions to combat corruption, restore democracy, and respect human rights. A… Read more

682. What does the August 06, 2019 regulatory amendment related to E.O. 13871 do?

682 … The regulatory amendment: (i) implements the correspondent or payable-through account sanctions set forth in section 2 of E.O. 13871 by incorporating those provisions in the Iranian Financial Sanctions Regulations, 31 C.F.R. part 561 (IFSR); (ii) renames the Iranian Human Rights Regulations,… Read more

582. I am located outside of the United States and seek to export goods from a third-country location in connection with activity for the maintenance or wind down of contracts or agreements with an entity listed on General License 12B (or any other entity in which a listed entity in 12B owns, directly or indirectly, a 50 percent or greater interest). Are such exports excluded from the authorization in General License 12B or otherwise subject to section 10 of SSIDES, as amended by section 228 of CAATSA, or section 5 of UFSA, as amended by section 226 of CAATSA?

582 … No. Although General License 12B does not authorize the exportation of goods from the United States, paragraph (d)(4) of General License 12B does not similarly apply to the exportation of goods from a third country to another location. … I am located outside of the United States and seek to… Read more

583. Why is OFAC issuing General License 12B, and what new activity does it authorize?

583 … OFAC issued General License 12B to address difficulties blocked U.S. persons are having accessing funds needed for authorized wind-down and maintenance activities. General License 12B explicitly permits originating and intermediary U.S. financial institutions to process funds transfers that… Read more

585. May U.S. persons do business with a foreign company in which blocked persons hold, individually or in the aggregate, a less than 50 percent interest? Are foreign persons, including foreign financial institutions, subject to sanctions under section 10 of SSIDES, as amended by section 228 of CAATSA, and section 5 of UFSA, as amended by section 226 of CAATSA, for doing business with a foreign company in which blocked persons hold, individually or in the aggregate, a less than 50 percent interest?

585 … If one or more blocked persons does not hold, individually or in the aggregate, a 50 percent or greater interest in a foreign company, the foreign company is not itself blocked by virtue of OFAC’s 50 percent rule , and U.S. persons generally are not prohibited from engaging in transactions… Read more

586. What transactions are authorized under wind-down General License (GL) 15L?

586 … GL 15L superseded GL 15K on April 25, 2022. While GL 15K authorized certain transactions and activities that were ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements involving GAZ Group, or any entity in which GAZ Group owns,… Read more

587. Under what circumstances can OFAC give further sanctions relief to GAZ Group or any other entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest?

587 … Consistent with OFAC regulations, parties may be removed by demonstrating a change in the circumstances that led to their designation. In the case of GAZ Group, absent other adverse information and consistent with the facts and circumstances of any petition for delisting, the path for the… Read more

589. Will foreign persons be subject to sanctions under the Section 5 of the Ukraine Freedom Support Act (UFSA) or Section 10 of the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act (SSIDES), as amended, respectively, by Sections 226 or Section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) for engaging in activities with GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest?

589 … As described in FAQs 542 , 545 , 574 , and 579 , a transaction will not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES , as amended by section 228 of CAATSA , and section 5 of UFSA , as amended by section 226 of CAATSA, if a U.S. person… 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?

590 … No. U.S. persons may engage in activities authorized by GL 15L that occur on or after May 22, 2018, except for activities involving blocked 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… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence