Frequently Asked Questions

1051. Is the export to the Russian Federation or import from the Russian Federation of goods, services, or technology considered “new investment” for the purposes of Russia-related Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”)?

1051 … The prohibitions on “new investment” pursuant to the respective E.O.s do not prohibit the export or import of goods, services, or technology, or related sales or purchases, to or from the Russian Federation, provided that such transaction is made pursuant to ordinary commercial sales terms (… Read more

1103. Is there a wind-down period for transactions involving Public Joint Stock Company Rosbank (Rosbank), which was blocked on December 15, 2022 pursuant to Executive Order (E.O.) 14024? What transactions are authorized during the wind-down period?

1103 … OFAC issued General Licenses (GL) 58 and 59 concurrent with the designation of Rosbank. GL 58 authorizes a wind-down period for transactions involving Rosbank or any entity in which Rosbank owns, directly or indirectly, a 50 percent or greater interest (“Rosbank entities”) until 12:01 a.m.… Read more

1104. Is Norilsk Nickel blocked as a result of the designation of Vladimir Potanin?

1104 … No. OFAC has not designated Norilsk Nickel and, based on information available to OFAC as of December 15, 2022, Norilsk Nickel is not owned 50% or more by blocked persons or otherwise considered the blocked property of Vladimir Potanin… Read more

1105. What actions did OFAC take to implement the United Nations Security Council Resolution (UNSCR) 2664 of December 9, 2022 relating to a new UN sanctions exception for humanitarian assistance?

1105 … On December 9, 2022, the United Nations (UN) Security Council adopted UNSCR 2664, which establishes a humanitarian carveout to the asset freeze measure across United Nations sanctions regimes. The carveout enables the flow of legitimate humanitarian assistance and activities supporting the… Read more

1107. For purposes of the OFAC general licenses related to the official business of certain international organizations and entities (IO GLs), what organizations are included within the United Nations’ “Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations”?

1107 … For an organizational chart of the United Nations (UN), which lists the UN Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations, including the World Bank, please see this page on the UN website . The IO GLs also authorize the… Read more

1108. Does OFAC’s issuance of general licenses (GLs) as outlined in FAQ 1105 restrict the scope of any existing exemptions or OFAC authorizations for humanitarian activities?

1108 … No. OFAC’s action of December 20, 2022 does not restrict the scope of any existing exemptions or OFAC authorizations for humanitarian activities, including existing general licenses authorizing certain NGO activities in sanctioned jurisdictions such as the Crimea Region of Ukraine, Iran,… Read more

1109. Are petroleum products of Russian Federation origin that are loaded onto a vessel at the port of loading for maritime transport prior to February 5, 2023 subject to the price cap?

1109 … No, provided the petroleum products are unloaded at the port of destination prior to 12:01 a.m., eastern daylight time, April 1, 2023. Petroleum products of Russian Federation origin that are loaded onto a vessel at the port of loading prior to 12:01 a.m., eastern standard time, February 5… Read more

213. Are United States financial institutions that do not hold correspondent or payable-through accounts for Bank of Kunlun required to block or reject transactions that otherwise involve Bank of Kunlun?

213 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . No. U.S. financial institutions are not required to block or reject financial or trade transactions that involve Bank of Kunlun. That said, we would expect… Read more

210. What are the consequences for a U.S. financial institution that maintains or opens a new correspondent or payable-through account for Bank of Kunlun?

210 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . A U.S. financial institution that maintains or opens a correspondent or payable-through account for Bank of Kunlun is subject to civil penalties in the… Read more

209. What happens to the correspondent and payable-through accounts held by Bank of Kunlun in the United States?

209 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . To our knowledge, Bank of Kunlun does not currently hold correspondent accounts with U.S. financial institutions. The July 31, 2012 action prohibits… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence