Frequently Asked Questions

661. What does General License 9H authorize with respect to Petróleos de Venezuela, S.A. (PdVSA) debt and equity and what are the implications for U.S. and non-U.S. persons?

General License (GL) 9H authorizes U.S. persons to engage in all transactions prohibited by subsection 1(a)(iii) of Executive Order (E.O.) 13808 or by E.O. 13850 , each as amended by E.O. 13857 , or by E.O. 13884 , as collectively incorporated into the Venezuela Sanctions Regulations, 31 CFR part… Read more

1246. Does General License 52 authorize the sale of certain shares of CITGO that are the subject of Crystallex International Corporation v. Bolivarian Republic of Venezuela?

No. A specific license will be required before any sale is executed in the Crystallex case. Notwithstanding the existence of any general licenses under the Venezuela Sanctions Regulations (VSR), a specific license from OFAC is required for the entry into a settlement agreement, or for the… Read more

1247. Do non-U.S. persons face sanctions risk for engaging in transactions authorized by General Licenses (GL) 46B, 51A, and 52?

No, provided that non-U.S. persons comply with certain conditions outlined in GLs 46B , 51A , and 52 , as described below. Subject to certain conditions, GLs 46B, 51A, and 52 authorize established U.S. entities to engage in certain transactions involving Petróleos de Venezuela, S.A. (PdVSA), as… Read more

956. For the Belarus, Russian Harmful Foreign Activities (Russia) Ukraine-/Russia-related, and Venezuela-related sanctions programs, how does OFAC view modifications to pre-existing loans, contracts, or other agreements to replace London Interbank Offered Rate (LIBOR) as the reference rate?

In July 2017, the United Kingdom Financial Conduct Authority (FCA) announced the "future cessation and loss of representativeness" of the ICE Benchmark Administration's 35 global reference rates, the LIBOR rates. In light of the discontinuation of LIBOR as a benchmark reference rate, OFAC is… Read more

1248. Since January 2026, OFAC has issued a series of Venezuela-related General Licenses related to purchases and investment in Venezuela's natural resource sectors, such as Venezuela-related General Licenses (GLs) 48A and 50A, that include a reporting requirement. Which parties are responsible for providing such reports pursuant to those General Licenses?

In general, the parties engaged in the primary authorized activity are responsible for complying with the applicable reporting requirements in these Venezuela-related GLs. Parties that are only indirectly involved or providing services ancillary to the primary authorized activity are not required… Read more

1250. Are Iranian digital asset exchanges blocked under OFAC sanctions?

Yes. Executive Order (E.O.) 13599 , as implemented by section 560.211(b) of the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), blocks the property and interests in property of Iranian financial institutions. An Iranian financial institution is blocked pursuant to E.O. 13599… Read more

1251. What does Executive Order (E.O.) 14404 of May 1, 2026, "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to U.S. National Security and Foreign Policy," do?

E.O. 14404 takes additional steps with respect to the national emergency declared in E.O. 14380 of January 29, 2026, "Addressing Threats to the United States by the Government of Cuba." E.O. 14404 authorizes the imposition of sanctions by the Secretary of the Treasury and the Secretary of State on… Read more

1254. On May 7, 2026, the Department of State designated the Cuban entity Grupo de Administración Empresarial S.A. (GAESA) pursuant to E.O. 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with GAESA?

Generally, yes, but the U.S. government does not intend to target foreign persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the wind down of transactions involving GAESA, or any entity in which GAESA owns, directly or indirectly, a 50… Read more

1253. What does Cuba-related General License (GL) 1, "Transactions Authorized Pursuant to the Cuban Assets Control Regulations," authorize?

On May 7, 2026, OFAC issued Cuba-related GL 1 , authorizing all transactions prohibited by E.O. 14404 where such transactions are authorized or exempt under the Cuban Assets Control Regulations, 31 CFR part 515 ( CACR ). GL 1 includes transactions authorized by either general or specific license… Read more

1256. Are all persons that operate or have operated in the five sectors of the Cuban economy identified in E.O. 14404 sanctioned by OFAC under E.O. 14404?

No. E.O. 14404 authorizes the Secretary of the Treasury, in consultation with the Secretary of State, or the Secretary of State, in consultation with the Secretary of the Treasury, to impose blocking sanctions on any foreign person determined to operate or have operated in the following sectors of… Read more

Frequently Asked Questions

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