Frequently Asked Questions

944. What constitutes “debt” pursuant to Directive 1 under E.O. 14038?

944 … The term debt includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers’ acceptances, discount notes or bills, or commercial paper. … What constitutes “debt” pursuant to Directive 1 under E.O. …

945. Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in all activities with the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus?

945 … No. Directive 1 under E.O. 14038 prohibits U.S. persons from engaging in only certain activities with the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus, as explained in FAQ 940 . All other activities with the Ministry of Finance of the… Read more

946. Can U.S. financial institutions continue to maintain correspondent accounts and process U.S. dollar-clearing transactions for the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus?

946 … Yes. U.S. financial institutions may continue to maintain correspondent accounts and process U.S. dollar-clearing transactions for the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus, provided such activity is not otherwise prohibited… Read more

947. If a U.S. person entered into a revolving credit facility or long-term loan agreement for a person determined to be subject to Directive 1 under E.O. 14038 prior to December 2, 2021, what are the restrictions on drawdowns from that facility? Do all drawdowns and disbursements pursuant to the parent agreement need to carry repayment terms of 90 days or less?

947 … If a U.S. person entered into a revolving credit facility or long-term loan agreement prior to December 2, 2021, drawdowns and disbursements with repayment terms of 90 days or less are permitted. In addition, drawdowns and disbursements whose repayment terms exceed 90 days are not prohibited… Read more

948. Does Directive 1 under E.O. 14038 prohibit U.S. persons from entering into derivatives contracts linked to new debt issued by the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus?

948 … Yes. Transactions by U.S. persons and within the United States involving derivative products whose value is linked to an underlying asset that constitutes prohibited debt issued by a person subject to Directive 1 under E.O. 14038 are prohibited, unless otherwise authorized by the Office of… 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?

949 … No. The Taliban are designated as a Specially Designated Global Terrorist (SDGT) Executive Order (E.O.) 13224, as amended . The Haqqani Network is designated as an SDGT under E.O. 13224, as amended, and a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and… Read more

951. Is Afghanistan subject to comprehensive sanctions?

951 … No. In contrast to sanctions programs administered and enforced by OFAC with regard to North Korea, Cuba, Iran, Syria, and the Crimea and so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine, there are no comprehensive sanctions on Afghanistan. Therefore,… Read more

952. When operating in Afghanistan, how can I tell who is a member of the Taliban or the Haqqani Network, which are designated are Specially Designated Global Terrorists (SDGT) under U.S. counter terrorism sanctions?

952 … A number of members of the Taliban and/or the Haqqani Network are explicitly included on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) . Persons operating in Afghanistan can use OFAC’s SDN List Search Tool to identify such members of the Taliban or the Haqqani… Read more

953. Do U.S. sanctions on the Taliban and the Haqqani Network prohibit moving or sending money into or out of Afghanistan? Do U.S. sanctions prohibit or require a particular method of payment for moving or sending money into or out of Afghanistan?

953 … No. U.S. sanctions on the Taliban and the Haqqani Network do not prohibit the movement of funds into or out of Afghanistan, provided that the transactions do not involve blocked individuals or entities, or property in which a blocked person has an interest. In addition, OFAC has issued… Read more

954. Are purchases of fuel, payment for telecommunications services, payment for security services, payment of rent, and payment of utilities by nongovernmental organizations (NGOs) considered ordinarily incident and necessary to authorized activities under Afghanistan-related General Licenses (GLs) 14, 15, and 19? Are such transactions covered by Afghanistan-related GL 20?

954 … The purchases of fuel, payment for telecommunications services, payment for security services, payment of rent, and payment of utilities may be authorized under 14 , 15 , and 19 provided that they are ordinarily incident and necessary to effectuate the activities authorized by the GLs. As… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence