Frequently Asked Questions

50. Is there a requirement for annual reporting of blocked property? Is there a required format?

… 50 … 50 …

581. I am a U.S. person that seeks to supply goods to RUSAL. Am I permitted to export those goods from the United States to RUSAL pursuant to General License 14?

… restrict exports to RUSAL (or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest), provided that the activity is for maintenance or wind down and … restrict exports to RUSAL (or any other entity in which RUSAL owns, directly or… Read more

1055. Do the new investment prohibitions of Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”) prohibit U.S. persons from lending funds to, or purchasing a debt or equity interest in, entities located outside of the Russian Federation?

… Federation and (ii) the entity located outside the Russian Federation derives less than 50 percent of its revenues from its investments in the Russian Federation. For the purposes of … a debt or equity interest in an entity located outside of the Russian Federation that derives… Read more

567. I am a U.S. person employee or work at an office of a company that was designated under E.O. 13661 or E.O. 13662, or blocked by operation of law pursuant to OFAC’s 50 percent rule on April 6, 2018 as a result of such a designation. What am I authorized to do with respect to continuing activities of the blocked entity?

… blocked entities listed in General License 12A, including entities blocked pursuant to OFAC’s 50 percent rule, you are prohibited from engaging in transactions with such individual or entity, … designated under E.O. 13661 or E.O. 13662, or blocked by operation of law pursuant to… Read more

1131. Is LETTERONE HOLDINGS S.A. (LetterOne) blocked as a result of the designation of Petr Olegovich Aven, Mikhail Maratovich Fridman, German Borisovich Khan, and Alexey Viktorovich Kuzmichev?

… not designated LetterOne and, based on information available to OFAC, LetterOne is not owned 50 percent or more by blocked persons or otherwise considered the blocked property or interest in … not designated LetterOne and, based on information available to OFAC, LetterOne is not… Read more

932. Do U.S. sanctions prohibit U.S. persons from visiting, or making donations to, the Imam Reza Holy Shrine in Mashhad, Iran?

… The Holy Shrine Organization is also considered blocked under E.O. 13876 pursuant to OFAC's 50 Percent Rule to the extent it is 50 percent or more owned by AQR. More information about OFAC's 50 Percent Rule is available at https://ofac.… Read more

663. Does the Secretary of the Treasury’s determination on March 22, 2019, that persons operating in the financial sector of the Venezuelan economy may be subject to sanctions pursuant to Executive Order 13850, as amended, mean that all Venezuelan financial institutions have been sanctioned by OFAC as of March 22, 2019, and are now blocked persons?

… those persons listed on OFAC’s SDN List, and entities that they own, directly or indirectly, 50 percent or more of, are blocked persons and subject to sanctions pursuant to E.O. 13580 , as … those persons listed on OFAC’s SDN List, and entities that they own, directly or… Read more

817. What is the significance of OFAC’s designations of Rosneft Trading S.A. and TNK Trading International S.A.? Do the E.O. 13850 blocking sanctions on Rosneft Trading S.A. and TNK Trading International S.A. apply to their corporate parent and their affiliates?

… which Rosneft Trading S.A. or TNK Trading International S.A. owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m. eastern daylight time, May 20, 2020. After the … which Rosneft Trading, S.A. or TNK Trading International S.A. owns, directly or… Read more

949. Do sanctions administered by the Office of Foreign Assets Control (OFAC) on the Taliban and the Haqqani Network prohibit the sending of personal remittances to Afghanistan?

… or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, that are prohibited by the Global Terrorism Sanctions … or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50… Read more

894. What does Russia-related General License (GL) 1B authorize?

… and activities involving MRS, or any entity in which MRS owns, directly or indirectly, a 50 percent or greater interest, that are not related to the construction of the Nord Stream 2 … identified as blocked property of any entity in which MRS owns, directly or indirectly, a… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence