Frequently Asked Questions

568. I am a U.S. person, and I am also an employee, or sit on the board, of an entity that was either 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. Can I continue to be employed by or sit on the board of a blocked entity? What am I allowed to do with respect to severing ties with the entity?

568 … Absent authorization from OFAC, your continued employment or board membership with such an entity is prohibited. You should review the actions you view as necessary to sever your ties with the blocked entity against applicable OFAC regulations, authorizations, and public guidance. If, after… Read more

569. A U.S. company had ordered goods from 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. May the U.S. company still accept the goods?

569 … Yes, provided that the importation is in accordance with the requirements and limitations specified in General License 12A . For the limited period of time specified in the general license, General License 12A authorizes all transactions ordinarily incident and necessary to the maintenance or… 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?

570 … Until 12:01 a.m. eastern daylight time, May 25, 2022, General License (GL) 13R authorizes certain divestment and transfer activities related to debt, equity, or other holdings in GAZ Group, or in entities in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, that… Read more

571. I am a U.S. person holding accounts for or other property of an entity or individual 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. Does General License (GL) 13R allow me to unblock this property?

571 … No. Until 12:01 a.m. eastern daylight time, May 25, 2022, GL 13R authorizes certain divestment and transfer activities related to debt, equity, or 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… Read more

572. Prior to April 6, 2018, E.O. 13662 only applied to OFAC’s Ukraine-/Russia-related sectoral sanctions and identifications under the Sectoral Sanctions Identification List. Why is OFAC designating individuals and entities under E.O. 13662?

572 … Although E.O. 13662 provides OFAC the authority to impose sectoral sanctions on specified persons operating in sectors of the Russian economy as implemented through Directives 1-4 , OFAC may also designate persons as blocked under E.O. 13662. Unlike with SSI entities, U.S. persons must block… Read more

573. A person 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 holds an ownership interest of less than fifty percent in a U.S. company. In such a scenario, how does the U.S. company comply with U.S. sanctions?

573 … If one or more blocked persons in such a scenario does not hold a 50 percent or more interest in the U.S. company, the U.S. company is not itself blocked, but the U.S. company must block all property and interests in property in which the blocked person has an interest. See OFAC’s 50 percent… Read more

614. What does E.O. 13846 do with respect to Iran’s energy, petroleum, and petrochemical sectors?

614 … E.O. 13846 reimposes sanctions previously set out in E.O.s 13622, 13628, and 13645 with respect to the Iranian energy, petroleum, and petrochemical sectors. As such, subsections 1(a)(ii) and (2)(a)(ii) of E.O. 13846 authorize blocking sanctions and correspondent or payable-through account… Read more

615. Does E.O. 13846 mean that Iran’s trade partners should no longer buy petroleum products from Iran? How will this affect exports of Iranian oil?

615 … These measures, which apply to transactions occurring on or after November 5, 2018, establish a key element of the comprehensive Iran sanctions framework by deterring work-around financial transactions involving NIOC or NICO that were not being captured under the sanctions previously… Read more

616. Can countries that receive a significant reduction exception under NDAA 2012 purchase oil through NIOC and NICO without facing sanctions?

616 … All property and interests in property of NIOC and NICO subject to U.S. jurisdiction are already blocked pursuant to E.O. 13599, and U.S. persons are prohibited from all dealings with these entities. E.O. 13846 reestablishes the authority previously contained in E.O. 13622 to sanction FFIs… Read more

617. E.O. 13846 targets transactions between foreign financial institutions and NIOC and NICO. What about a NIOC or NICO subsidiary? Are transactions with those entities also sanctionable under this E.O.?

617 … Yes. As in E.O. 13622, E.O. 13846 defines NIOC and NICO to include any entity owned or controlled by, or operating for or on behalf of, NIOC and NICO. … E.O. 13846 targets transactions between foreign financial institutions and NIOC and NICO. What about a NIOC or NICO subsidiary? Are… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence