Frequently Asked Questions

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

1254. On May 7, 2026, the Department of State designated the Cuban entity Grupo de Administración Empresarial S.A. (GAESA) pursuant to E.O. 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with GAESA?

… of transactions involving GAESA, or any entity in which GAESA owns, directly or indirectly, a 50 percent or greater interest, through June 5, 2026. However, non-U.S. persons, including FFIs, … transactions involving GAESA, or any entity in which GAESA owns, directly or indirectly… 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

568. I am a U.S. person, and I am also an employee, or sit on the board, of an entity that was either 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. Can I continue to be employed by or sit on the board of a blocked entity? What am I allowed to do with respect to severing ties with the entity?

… 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. Can I continue to be employed … designated under E.O. 13661 or E.O. 13662, or blocked by operation of law pursuant to… 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

1276. On October 15, 2026, the Department of State designated the Banco Internacional de Comercio, S.A. (BICSA) pursuant to Executive Order (E.O.) 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with BICSA?

… of transactions involving BICSA, or any entity in which BICSA owns, directly or indirectly, a 50 percent or greater interest, through November 14, 2026. However, non-U.S. persons, including … transactions involving BICSA, or any entity in which BICSA owns, directly or indirectly… Read more

595. What does Venezuela-related General License 5AA authorize?

… as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV. One effect of subsection 1(a)(iii) is to require authorization … persons may engage in certain transactions regarding any equity interest in an entity owned… Read more

814. I am currently in possession of artwork in which a Specially Designated Global Terrorist (SDGT) has an interest. What should I do?

… U.S. persons must also comply with all other applicable reporting obligations. See FAQs 49 and 50. Questions about whether a transaction should be blocked should be directed to the OFAC … U.S. persons must also comply with all other applicable reporting obligations. See FAQs 49… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence