Frequently Asked Questions

1116 … No. The Director of OFAC, in consultation with the State Department, has issued a determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy.… Read more

1119 … Iran GL O authorizes U.S. persons to wind down all transactions otherwise prohibited by section 5 of Executive Order 13846 involving any vessel blocked as part of the March 2, 2023 designation (“blocked vessels”), subject to certain conditions.  This includes, among other activities, the… Read more

1120 … No.  Non-U.S. persons generally do not risk exposure to sanctions for engaging in activities or facilitating transactions for such activities that would be authorized for U.S. persons pursuant to GL O .  Non-U.S. persons unable to wind down transactions in accordance with Iran GL O before 12… Read more

938 … The GL at § 542.516 of the SySR authorizes NGOs to engage in activities in support of certain non-commercial activities in Syria, including:  humanitarian projects to meet basic human needs; democracy-building; education; non-commercial development projects directly benefitting the Syrian… Read more

939 … GL 5 authorizes, through 12:01a.m. eastern standard time, April 1, 2022, all transactions and activities prohibited by Executive Order (E.O.) 14038 that are ordinarily incident and necessary to the wind down of transactions involving Open Joint Stock Company Belarusian Potash Company (BPC) or… Read more

940 … Pursuant to Directive 1 under E .O. 14038 , the following activities by U.S. persons or within the United States are prohibited, except to the extent provided by law or unless licensed or otherwise authorized by the Office of Foreign Assets Control:  all transactions in, provision of… Read more

941 … Yes. … Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in dealings in both the primary and secondary markets for new debt with a maturity of greater than 90 days issued on or after December 2, 2021 by the Ministry of Finance of the Republic of Belarus or the Development… Read more

942 … No, so long as the terms of such debt (including the repayment period, the interest rate, and the amount) were contractually agreed to before December 2, 2021 and are not modified on or after December 2, 2021. … Does Directive 1 under E.O. 14038 prohibit U.S. persons from engaging in dealings… Read more

943 … No.  The prohibitions in Directive 1 do not apply to any entity that is owned, directly or indirectly, 50 percent or more by the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus, whether individually or in the aggregate. … Does the 50 Percent… Read more

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. …