Frequently Asked Questions

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

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

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

923. Do blocking sanctions imposed on persons pursuant to Executive Order (E.O.) of September 17, 2021, “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” automatically apply to entities owned in whole or in part by sanctioned persons?

… Persons List (SDN List), it is not blocked pursuant to E.O. of September 17, 2021. OFAC’s 50 Percent Rule does not apply to persons blocked solely pursuant to section 2(a)(i)(A) of E.O. … Persons List (SDN List), it is not blocked pursuant to E.O. of September 17, 2021. OFAC’s… Read more

9. What does OFAC mean when it refers to "blocked" property? How does OFAC define “property”?

… (SDN List), foreign governments subject to blocking, and persons blocked pursuant to OFAC’s “ 50 Percent Rule .” For further information, see FAQ 401 and OFAC guidance on the "50 Percent Rule." The term "property," as defined in various OFAC… Read more

1265. On August 20, 2026, the Department of State designated the Ministry of Construction of Cuba (MICONS) pursuant to E.O. 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with MICONS?

… transactions involving MICONS, or any entity in which MICONS owns, directly or indirectly, a 50 percent or greater interest, through September 19, 2026. However, non-U.S. persons, including … transactions involving MICONS, or any entity in which MICONS owns, directly or… Read more

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

… 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 (a prior … which Rosneft Trading S.A. or TNK Trading International S.A. owns, directly or… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence