Frequently Asked Questions

1204. On December 27, 2024, OFAC designated Bidzina Ivanishvili (Ivanishvili) pursuant to Executive Order (E.O.) 14024. Can I continue to engage in transactions or other dealings with entities owned by Ivanishvili that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

… License (GL) 116 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ivanishvili provided that such entity is not identified on the SDN List. Non-U.S. … License (GL) 116 authorizing U.S. persons to engage in all transactions with any entity… Read more

1074. Is EuroChem Group AG blocked as a result of the designation of Andrey Igorevich Melnichenko?

… EuroChem Group AG and, based on information available to OFAC, EuroChem Group AG is not owned 50% or more by blocked persons or otherwise considered the blocked property of Andrey Igorevich … EuroChem Group AG and, based on information available to OFAC, EuroChem Group AG is not… Read more

1075. Is PhosAgro PJSC blocked as a result of the designation of Andrey Grigoryevich Guryev and Andrey Andreevich Guryev?

… PhosAgro PJSC and, based on information available to OFAC, PhosAgro PJSC is not owned 50% or more by blocked persons or otherwise considered the blocked property of Andrey … PhosAgro PJSC and, based on information available to OFAC, PhosAgro PJSC is not owned 50… Read more

930. Do U.S. sanctions on the Taliban and the Haqqani Network prohibit the exportation or reexportation of agricultural commodities, medicine, and medical devices to Afghanistan?

… Network, or any entity in which Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest, subject to certain conditions. GL 15 also authorizes U.S. … or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a… Read more

653. I am the manager of a Synthetic Exchange Traded Fund (ETF), which tracks a basket of debt, equity or other holdings in order to provide a return approximating the returns on that basket, but which does not actually hold the underlying debt, equity, or other holdings contained in the basket. May I continue to offer such funds, and may U.S. persons trade in shares of these funds, if the underlying basket being tracked contains holdings in an entity or entities that appear 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

589. Will foreign persons be subject to sanctions under the Section 5 of the Ukraine Freedom Support Act (UFSA) or Section 10 of the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act (SSIDES), as amended, respectively, by Sections 226 or Section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) for engaging in activities with GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest?

… in activities with GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest? … in activities with GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest? …

988. Does Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prohibit U.S. persons from engaging in all activities with entities subject to it?

… as explained in FAQ 984 . Please see FAQ 985 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive. Some entities determined to be subject to the … as explained in FAQ 984 . Please see FAQ 985 regarding the applicability of OFAC’s 50… Read more

1069. What does Nicaragua General License (GL) 3 authorize?

… de Minas (ENIMINAS), or any entity in which ENIMINAS owns, directly or indirectly, a 50 percent or greater interest (collectively, “Blocked ENIMINAS Entities”), through 12:01 a.m. … de Minas (ENIMINAS), or any entity in which ENIMINAS owns, directly or indirectly, a 50… Read more

1201. What authorizations exist for diplomatic or consular missions operating in or outside of Russia and Russian diplomatic or consular missions operating abroad?

… and involve Gazprombank, or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest, or are prohibited by Directive 4 under E.O. 14024 , "Prohibitions … and involve Gazprom Neft, or any entity in which Gazprom Neft owns, directly or… Read more

1140. In light of the designation of Orka Holding, are U.S. persons authorized to engage in transactions related to the provision of medicine, medical devices, and medical services involving Orka Holding and its subsidiaries?

… in which Orka Holding AD owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. Non-U.S. persons generally do not risk exposure to sanctions for … in which Orka Holding AD owns, directly or indirectly, individually or in the aggregate, a… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence