Frequently Asked Questions

1033. What actions were taken on May 8, 2022 related to certain accounting, trust and corporate formation, and management consulting services?

1033 … On May 8, 2022, the Director of OFAC, in consultation with the Department of State, issued a determination pursuant to Executive Order (E.O.) 14071 , "Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services," prohibiting the exportation,… Read more

1034. For the purposes of the determination of May 8, 2022 made pursuant to Executive Order (E.O.) 14071, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” what is meant by the terms “accounting,” “trust and corporate formation,” and “management consulting” services?

1034 … For the purposes of the determination of May 8, 2022 made pursuant to E.O. 14071 , OFAC anticipates publishing regulations defining these terms to include the following: “Accounting services” – includes services related to the measurement, processing, and evaluation of financial data about… Read more

1035. For the purposes of Russia-related General License 35 what is meant by the terms “credit rating services” and “auditing services?”

1035 … The term “credit rating services” means services related to assessments of a borrower’s ability to meet financial commitments, including analysis of general creditworthiness or with respect to a specific debt or financial obligation. The term “auditing services” means examination or… Read more

1036. When do the prohibitions imposed by the determination of May 8, 2022 made pursuant to Executive Order (E.O.) 14071, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” take effect?

1036 … The prohibitions imposed by the determination of May 8, 2022 made pursuant to E.O. 14071 take effect at 12:01 a.m. eastern daylight time June 7, 2022. In addition, OFAC has issued General License 34 to authorize all transactions ordinarily incident and necessary to the wind down of the… Read more

1038. For the purposes of the determination of May 8, 2022 made pursuant to Executive Order (E.O.) 14024, what is meant by the terms “accounting,” “trust and corporate formation services,” and “management consulting” sectors of the Russian Federation economy?

1038 … For the purposes of the determination of May 8, 2022 made pursuant to E.O. 14024 , OFAC interprets the following terms to include activities related to products and services in or involving the Russian Federation in the following: “Accounting sector” – includes the measurement, processing,… Read more

1039. Are transactions ordinarily incident and necessary to the exportation or reexportation of agricultural commodities to, from, or transiting the Russian Federation that involve Agropromyshlennyi Kompleks Voronezhskii OOO, Anninskii Elevator OOO, and Azovskaya Zernovaya Kompaniya OOO authorized under OFAC sanctions?

1039 … Yes. On May 8, 2022, OFAC designated Agropromyshlennyi Kompleks Voronezhskii OOO, Anninskii Elevator OOO, and Azovskaya Zernovaya Kompaniya OOO pursuant to Executive Order (E.O.) 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or… Read more

1040. Are transactions related to telecommunications and certain internet-based communications that involve persons designated pursuant to Executive Order 14024 authorized by Russia-related General License (GL) 25G?

1040 … GL 25G authorizes certain transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR). In addition, GL 25G… Read more

1189. What additional authorizations did Treasury issue on August 23, 2024 with respect to certain diamonds and diamond jewelry prohibited by Executive Order (E.O.) 14068?

1189 … Treasury issued two general licenses (GLs), GL 103 and GL 104, authorizing certain transactions with respect to certain diamonds and diamond jewelry that would otherwise be prohibited by E.O. 14068 in “Prohibitions Related to Imports of Certain Categories of Diamonds” (the “ Diamonds… Read more

1190. Do U.S. sanctions target persons for engaging in political speech, religious practice, or other constitutionally protected activities?

1190 … OFAC does not sanction persons for their engagement in activities subject to U.S. constitutional protection, such as protected speech or religious practice or for their religious beliefs; nor do U.S. persons violate OFAC sanctions for engaging in such constitutionally protected activity.… Read more

1191. On September 12, 2024, OFAC designated Ly Yong Phat (Ly), L.Y.P. Group Co., LTD (L.Y.P. Group), and the following entities owned by L.Y.P. Group under the Global Magnitsky sanctions authority: O-Smach Resort, Garden City Hotel, Koh Kong Resort, and Phnom Penh Hotel. Can I continue to engage in transactions or other dealings with other entities owned by Ly or L.Y.P. Group that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

1191 … Yes. Although transactions or other dealings involving Ly and L.Y.P. Group are prohibited as a result of OFAC's designation, OFAC concurrently issued Global Magnitsky General License (GL) 8 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ly or the… Read more

Frequently Asked Questions

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