Frequently Asked Questions

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

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

995. Does Afghanistan-related General License (GL) 20 authorize financial transfers to governing institutions in Afghanistan, including the Central Bank of Afghanistan (Da Afghanistan Bank, or DAB), or state-owned or -controlled companies and enterprises in Afghanistan? Does Afghanistan-related GL 20 authorize receipt of payment from governing institutions in Afghanistan and state-owned or -controlled companies and enterprises in Afghanistan?

… or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, or any blocked individual who is in a leadership role of a … or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a … 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?

… 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 … 12B (or any other entity in which a listed entity in 12B owns, directly or indirectly, a… Read more

116. On February 14, 2008, OFAC issued guidance stating that the property and interests in property of an entity are blocked if the entity is owned, directly or indirectly, 50% or more by a person whose property and interests in property are blocked pursuant to an Executive Order or regulations administered by OFAC. We act as an intermediary bank in wire transfers between other banks. Does OFAC expect banks that are acting as financial intermediaries to research non-account parties that do not appear on the SDN List, but are involved with or referenced in transactions that are processed on behalf of correspondents?

… A wire transfer in which an entity has an interest is blocked property if the entity is 50% or more owned by a person whose property and interests in property are blocked. This is true … interests in property of an entity are blocked if the entity is owned, directly or indirectly… Read more

1103. Is there a wind-down period for transactions involving Public Joint Stock Company Rosbank (Rosbank), which was blocked on December 15, 2022 pursuant to Executive Order (E.O.) 14024? What transactions are authorized during the wind-down period?

… transactions involving Rosbank or any entity in which Rosbank owns, directly or indirectly, a 50 percent or greater interest (“Rosbank entities”) until 12:01 a.m. eastern daylight time, March … For individuals holding accounts at Rosbank entities, see FAQ 1080 for guidance,… Read more

827. What does Nicaragua-related General License (GL) 2 authorize with respect to the Nicaraguan National Police?

… wind down transactions involving any entity in which NNP owns, directly or indirectly, a 50 percent or greater interest. OFAC’s designation of the NNP is directed at the NNP as an … wind down transactions involving any entity in which NNP owns, directly or indirectly, a … Read more

857. Do the prohibitions in Executive Order (E.O.) 13959, as amended, apply to purchases or sales of publicly traded securities of subsidiaries of entities listed on the Non-SDN Chinese Military-Industrial Complex Companies List (the “NS-CMIC List”)

… to E.O. 13959, as amended, or identified in the Annex of E.O. 13959, as amended. OFAC’s 50 percent rule does not apply to entities listed solely pursuant to E.O. 13959, as amended. … to E.O. 13959, as amended, or identified in the Annex of E.O. 13959, as amended. OFAC’s… Read more

652. Is it permissible for mutual funds and exchange traded funds (collectively, “funds”) that are U.S. persons to buy, sell, or otherwise engage in transactions related to debt, equity, or other holdings in an entity that appears on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), or of an entity owned 50 percent or more, individually or in the aggregate, by an individual or entity on the SDN List?

… List of Specially Designated Nationals and Blocked Persons (SDN List), or of an entity owned 50 percent or more, individually or in the aggregate, by an individual or entity on the SDN List? … List of Specially Designated Nationals and Blocked Persons (SDN List), or of an entity… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence