Frequently Asked Questions

1168. What action did Treasury take on April 12, 2024 with regards to aluminum, copper, and nickel of Russian Federation origin?

1168 … On December 6, 2023, and February 24, 2024, the G7 Leaders issued statements signaling their intent to reduce Russia’s revenues from metals. On April 12, 2024, in coordination with the United Kingdom, the United States issued two new prohibitions that will further disrupt the revenue that… Read more

1169. What is prohibited by the determination “Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14071 (the “Metals Services Determination”)?

1169 … The Metals Services Determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of the following categories of services to any person located in the Russian Federation: warranting… Read more

1170. For the purposes of the determination “Prohibitions Related to Imports of Aluminum, Copper, and Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114, (the “Metals Import Determination”) and the determination “Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14071 (the “Metals Services Determination”), what is meant by the terms “aluminum,” “nickel,” and “copper”?

1170 … For the purposes of the Metals Import Determination and the Metals Services Determination , OFAC anticipates publishing regulations defining “aluminum,” “nickel,” and “copper” to include articles or products defined at the following Harmonized Tariff Schedule of the United States (HTSUS)… Read more

1171. Do the determinations “Prohibitions Related to Imports of Aluminum, Copper, and Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114, (the “Metals Import Determination”) and the determination “Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14071 (the “Metals Services Determination”) apply to aluminum, copper, or nickel that has been incorporated or substantially transformed into other products outside of the Russian Federation?

1171 … No. FAQ 1019 clarifies that, for purposes of E.O. 14068 , as amended by E.O. 14114 , and the Metals Services Determination , the term “Russian Federation origin” excludes “any Russian Federation origin good that has been incorporated or substantially transformed into a foreign-made product… Read more

1172. Does the determination “Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14071 (the “Metals Services Determination”) impose new prohibitions on banks acting as intermediaries for payments related to Russian metals?

1172 … No. The processing, clearing, or sending of payments related to Russian metals by a U.S. bank on behalf of non-U.S. persons is not prohibited by the Metals Services Determination where the bank: (1) is operating solely as an intermediary; and (2) does not have any direct relationship with… Read more

1173. What are “user authentication services” for purposes of the general license in 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?

1173 … User authentication services are services used to login or verify the identity of a user to a particular software or service, such as a user identification account often used to login to email, mobile app stores, or other activities authorized by 31 CFR § 560.540 . … What are “user… Read more

5. How do I determine if I have a valid OFAC match?

5 … If you are calling about a wire transfer or other "live" transaction: Step 1. Is the "hit" or "match" against OFAC's Specially Designated Nationals (SDN) list, one of its other sanctions lists, or targeted countries, or is it "hitting" for some other reason (i.e., "Control List" or "PEP," "CIA… Read more

1150. What does determination of December 22, 2023, "Determination Pursuant to Section 11(a)(ii) of Executive Order (E.O. 14024)" (Russia Critical Items Determination) do?

1150 … The Russia Critical Items Determination issued pursuant to subsection 11(a)(ii) of E.O. 14024 identifies certain items that support Russia's military-industrial base. Foreign financial institutions (FFIs) may be sanctioned for having conducted or facilitated any significant transaction or… Read more

1224. What activities does OFAC General License 131, "Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities," authorize?

1224 … On October 22, 2025, OFAC designated PJSC Lukoil (Lukoil) to increase pressure on Russia's energy sector and degrade Russia's ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the… Read more

1225. What activities do Russia-related General Licenses 128B and 131 authorize?

1225 … Russia-related General License (GL) 128B , issued on December 4, 2025, authorizes through April 29, 2026 transactions involving Lukoil International GmbH (LIG), or any of its majority-owned subsidiaries, including Lukoil North America LLC and Lukoil Americas Corporation, (collectively, "LIG… Read more

Frequently Asked Questions

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