Frequently Asked Questions

1004. Are U.S. persons required to block transactions involving entities subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)?

1004 … No. Although the prohibitions of the Russia-related Sovereign Transactions Directive effectively immobilize any assets of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, the “… Read more

1005. Does Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive), prohibit trading in the secondary markets for Russian sovereign debt?

1005 … No, the Russia-related Sovereign Transactions Directive does not prohibit trading in the secondary markets for debt or equity of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively… Read more

1006. What does Executive Order (E.O.) 14065 do?

1006 … E.O. 14065 prohibits the following activities with the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine and such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the… Read more

1007. Are U.S. persons authorized to engage in certain activity with the so-called Donetsk People's Republic and Luhansk People's Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the "Covered Regions")?

1007 … U.S. persons are authorized through a variety of Ukraine-related general licenses (GLs) to support certain humanitarian efforts and other activity in the Covered Regions, including transactions related to the export of food or medicine, the response to the Coronavirus Disease 2019 (COVID-19… Read more

1008. Is there a wind-down period for the prohibitions imposed in Executive Order (E.O.) 14065?

1008 … Yes. Through 12:01 a.m. eastern daylight time on March 23, 2022, Ukraine-related General License 17 authorizes transactions that are ordinarily incident and necessary to the wind down of transactions involving the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR… Read more

1009. Does Executive Order (E.O.) 14065 block the entire Donetsk and Luhansk oblasts?

1009 … No. E.O. 14065 targets the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”). In… Read more

1010. My company transports Russian oil for sale to the United States and third countries. Can I continue to transport or sell Russian-origin oil without violating sanctions pursuant to Executive Order (E.O.) 14024?

1010 … The energy sector of the Russian Federation economy itself is not subject to comprehensive sanctions. However, prohibitions or restrictions may apply to certain energy-related transactions under several sanctions authorities, including prohibitions issued pursuant to E.O. 13662 , E.O. 14024… Read more

1046. Are U.S. persons required to divest their current holdings of Chinese Military-Industrial Complex Companies' (CMIC) securities before the end of the relevant 365-day divestment period pursuant to section 1(c) of Executive Order (E.O.) 13959, as amended?

1046 … U.S. persons are not required to divest their holdings of CMIC securities during the relevant 365-day divestment period and may continue to hold such securities after the divestment period. E.O. 13959, as amended, permits purchases or sales made solely to effect the divestment of CMIC… Read more

1047. For the purposes of Executive Order (E.O.) 13959, as amended, can holders of Chinese Military-Industrial Complex Companies' (CMIC) securities receive stock splits, cash dividends, or dividend reinvestments related to the covered securities, and are U.S. financial institutions allowed to process transactions related to this activity?

1047 … U.S. persons who hold securities of CMICs identified pursuant to E.O. 13959, as amended, may continue to receive cash dividends and stock splits related to such covered securities, and U.S. financial institutions may continue to process such transactions. However, purchases of CMIC… Read more

1048. After the relevant 365-day divestment period, are U.S. financial institutions required to block the attempted purchase or sale of Chinese Military-Industrial Complex Companies' (CMIC) securities covered by Executive Order (E.O.) 13959, as amended?

1048 … No. E.O. 13959, as amended, does not require U.S. financial institutions to block transactions. However, transactions that would be prohibited under E.O. 13959, as amended (including an attempted sale of covered securities by a U.S. person made to effect the divestment of CMIC securities… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence