Frequently Asked Questions

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

1260. Does the requirement in certain Venezuela General Licenses (e.g., 46C, 47A, 48B, 50B, 51B, 52A, and 54A) that the terms of contracts be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States mean that U.S. law must govern all aspects of the underlying activity?

No. Certain Venezuela general licenses (GLs) require that any contract for transactions authorized by the GL with the Government of Venezuela or certain other covered entities (e.g., Petróleos de Venezuela, S.A. in GL 52A or CVG Compañía General de Minería de Venezuela CA in GL 51B ) specify that… 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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence