Frequently Asked Questions

13. How can I report a possible violation of U.S. sanctions to OFAC? Will I receive "amnesty" if I report a possible violation to OFAC or if my failure to comply with U.S. sanctions was inadvertent?

… OFAC encourages anyone who may have violated OFAC-administered sanctions programs, or anyone who is aware of potential violations, to disclose the apparent or potential violation to OFAC. Voluntary self-disclosure to OFAC is considered a… Read more

998. What are the requirements of Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)?

… (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive; and (2) … transactions involving any Directive 4… Read more

43. Does a financial institution need to scan names against OFAC's list of targets upon account opening or can it wait for 24 hours to receive a report from its software vendor on whether or not there is a hit?

… or regulatory requirement to use software or to scan. There is a requirement, however, not to violate the law by doing business with a target or failing to block property. OFAC realizes that … against OFAC's list of targets upon account opening or can it wait for 24 hours to… Read more

1197. I'm a U.S. person with securities held at the National Settlement Depository (NSD), which were transferred pursuant to Russian Decree 840 to another Russian registrar. Am I required to block these securities?

… person other than those identified in the authorizations, and that any transfer made in violation of OFAC sanctions is null and void. As such, OFAC cautioned that U.S. persons should … should be treated as blocked. Any U.S. persons who have already filed initial blocking … Read more

36. I understand blocking a transaction, but what is meant by rejecting a transaction? When should a transaction be rejected rather than blocked?

… institution cannot so much as advise a letter of credit if the underlying transaction is in violation of OFAC regulations. In addition, U.S. persons are prohibited from facilitating … U.S. financial institution must reject the payment. Blocked and rejected transactions must be… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence