Frequently Asked Questions

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

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?

817 … On February 18, 2020, OFAC designated Rosneft Trading S.A. pursuant to E.O. 13850 for operating in the oil sector of the Venezuelan economy. Likewise, on March 12, 2020, OFAC designated TNK Trading International S.A. pursuant to E.O. 13850 for operating in the oil sector of the Venezuelan… Read more

818. Is there a wind-down period for transactions involving Rosneft Trading S.A. or TNK Trading International S.A.?

818 … OFAC issued General License(GL) 36A, which authorizes U.S. persons to engage in certain activities prohibited by E.O. 13850 necessary for the wind down of transactions involving Rosneft Trading S.A. or TNK Trading International S.A., or any entity in which Rosneft Trading S.A. or TNK Trading… Read more

819. Is the June 21, 2019 amendment to the Office of Foreign Assets Control (OFAC)'s Reporting, Procedures and Penalties Regulations in effect? Am I required to comply with all requirements of the amended regulations?

819 … Yes, effective June 21, 2019, OFAC amended the Reporting, Procedures and Penalties Regulations, 31 CFR part 501 (RPPR) , to provide updated instructions and incorporate new requirements for parties filing reports on blocked property, unblocked property, or rejected transactions. In addition,… Read more

883. What does Burma General License 4 authorize?

883 … Burma General License (GL) 4 authorizes, subject to certain conditions, all transactions and activities prohibited by Executive Order (E.O.) 14014 , that are ordinarily incident and necessary to the wind down of transactions involving, directly or indirectly, Myanmar Economic Corporation… Read more

884. Do non-U.S. persons, including nongovernmental organizations (NGOs) and foreign financial institutions, risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019 (Caesar Act) for activities that would be authorized under the Syrian Sanctions Regulations (SySR)?

884 … With respect to non-U.S. persons, OFAC will not consider transactions to be “significant” for the purpose of a sanctions determination under the Caesar Act if U.S. persons would not require a specific license from OFAC to participate in such a transaction. See 31 CFR § 542.414. Accordingly… Read more

888. What does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) do?

888 … Pursuant to the Russia-related Sovereign Debt Directive , the following activities by a U.S. financial institution are prohibited: As of June 14, 2021, participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021 by the Central Bank of the Russian… Read more

886. What does Executive Order (E.O.) 14024, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation” do?

886 … E.O. 14024 establishes a new national emergency under which sanctions may be imposed against individuals and entities furthering specified harmful foreign activities of the Russian Federation. This national emergency is separate from the national emergency relating to the crisis in Ukraine,… Read more

887. Are persons identified pursuant to Executive Order (E.O.) 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy blocked pursuant to E.O. 14024?

887 … Persons identified pursuant to E.O. 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy are not subject to prohibitions under E.O. 14024 unless those persons are also sanctioned pursuant to E.O. 14024. For more… Read more

889. Does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) prohibit participation in the secondary market for bonds issued by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation?

889 … Yes (see FAQ 888 and FAQ 965 ). Date Updated: February 22, 2022 … Does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) prohibit participation in the secondary market for bonds… Read more

Frequently Asked Questions

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