OFAC FAQs
OFAC publishes hundreds of FAQs — its own guidance on how the sanctions programs work, from the 50% rule to General Licenses to blocking obligations. Here they are, grouped by topic.
Iran Sanctions
- My bank operates accounts for individuals living in Iran. OFAC has told us that these accounts cannot be operated. Does this mean that the accounts are blocked?#37
- Are U-Turn payments for Iran still permitted?#38
- I have an account with a W-8 showing an address in Iran. Is the account automatically restricted?#54
- I have a client that is in Iran to visit a relative. Do I need to restrict the account?#118
- What activities by foreign financial institutions can subject them to CISADA sanctions?#149
- Where can I find a list of Islamic Revolutionary Guard Corps (IRGC) affiliates and Iran-linked financial institutions “blocked pursuant to the International Emergency Economic Powers Act (IEEPA)”?#150
- How do the Iranian Financial Sanctions Regulations (IFSR) define “U.S. financial institutions”?#151
- How do the Iranian Financial Sanctions Regulations (IFSR) define “foreign financial institutions”?#152
- How do the Iranian Financial Sanctions Regulations (IFSR) define the term “knowingly”?#153
- How does the Treasury Department determine whether a transaction or financial service is “significant” for purposes of the Iranian Financial Sanctions Regulations (IFSR)?#154
- When are the prohibitions and strict conditions on foreign financial institutions’ correspondent accounts or payable-through accounts in the United States effective?#155
- How will U.S. and foreign financial institutions know that the Treasury Department has made such a finding?#156
- How will the Treasury Department enforce the Iranian Financial Sanctions Regulations (IFSR) with respect to U.S. entities?#157
- Can the application of any part(s) of the Iranian Financial Sanctions Regulations (IFSR) be waived by the Department of the Treasury?#158
- Where can I find the text of the Iranian Financial Sanctions Regulations?#159
- Section 1 of E.O. 13599 blocks all property and interests in property of the Government of Iran, including the Central Bank of Iran, and of all Iranian financial institutions, that are in the United States, that come within the United States, or that come within the possession or control of U.S. persons (including overseas branches). Can you provide further clarification about this provision of E.O. 13599?#160
- If all property and interests in property of the Government of Iran, including the Central Bank of Iran, and of all Iranian financial institutions are blocked, can I conduct transactions involving the Government of Iran that have been previously authorized by OFAC?#161
- Are U.S. persons still required to comply with the Iranian Transactions Regulations (ITR)?#162
- What are the differences and similarities between E.O. 13599 and the Iranian Transactions Regulations (ITR)?#163
- The Iranian Transactions Regulations (ITR) authorize U.S. depository institutions and U.S. registered brokers or dealers in securities to process transfers of funds to or from Iran if the transfer is a non-commercial, personal remittance. Are U.S. depository institutions and U.S. registered brokers or dealers in securities still authorized to process such payments to or from a Government of Iran-owned bank that is not otherwise designated pursuant to another part of 31 C.F.R. Chapter V?#164
- To what extent are U.S. persons expected to conduct enhanced due diligence to determine if transactions contain a Government of Iran interest?#165
- OFAC’s SDN List contains a list of entities identified by OFAC as being the Government of Iran. Should U.S. persons now block the property and interests in property of those entities?#166
- OFAC has granted my company a license under the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”) and the Iranian Transactions Regulations (ITR). Can I continue to conduct the licensed transaction?#167
- OFAC has issued me a (non-TSRA) specific license related to Iran, or the Government of Iran. Can I continue to conduct the licensed transactions?#168
- What is the NDAA?#169
- What activities can trigger sanctions on a foreign financial institution under the NDAA?#170
- Does the NDAA (National Defense Authorization Act) repeal or amend Section 104(c) of CISADA (the Comprehensive Iran Sanctions, Accountability, and Divestment Act)?#171
- How does Executive Order 13599, “Blocking Property of the Government of Iran and Iranian Financial Institutions,” and the blocking of all Iranian financial institutions affect the financial sanctions provisions in CISADA? Do CISADA sanctions now apply to financial transactions with any Iranian financial institution?#172
- Are there any exceptions to the sanctions provisions in the National Defense Authorization Act for Fiscal Year 2012 (as amended) (NDAA for FY 2012)?#173
- What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “owned or controlled by the government of a foreign country,” “food, medicine, and medical devices,” “foreign financial institution,” “Iranian financial institution,” “significantly reduced,” and “whether the price and supply of petroleum and petroleum products produced in countries other than Iran is sufficient”?#174
- What is the scope of “petroleum products” under the law?#175
- If oil is being provided as payment for an outstanding debt, is such a transfer considered a “financial transaction”?#176
- If the Central Bank of Iran (CBI) is involved in providing settlement services for a transaction, or is otherwise acting solely as an intermediary in a transaction between a non-designated Iranian bank and a foreign financial institution, is the foreign financial institution deemed to be engaging in a transaction with the CBI?#177
- Are barter trades involving the Central Bank of Iran (CBI) considered “financial transactions” under Section 1245?#178
- Does the definition of “significant financial transaction” exclude the passive holding of Central Bank of Iran (CBI) reserves? Is the U.S. willing to give assurances that this will not be a basis for sanctions?#179
- Are payments made under contracts existing prior to the date of enactment of the National Defense Authorization Act (NDAA) statute (December 31, 2011) exempted from the definition of “significant transactions”?#180
- Will the U.S. refrain from sanctioning foreign financial institutions that receive funds from the Central Bank of Iran (CBI) to repay loans? What if these loans were granted for projects that might be subject to the food, medicine, and medical device exemptions under the National Defense Authorization Act (NDAA)?#181
- Is there a difference between entities that have been designated by the United States Government for illicit conduct, such as proliferation of weapons of mass destruction or support for terrorism, and those that are being blocked under E.O. 13599? How can I tell which entities appear on the Specially Designated National (SDN) List for which reasons?#182
- Why did the President issue the GHRAVITY E.O.?#183
- What does the GHRAVITY E.O. do?#184
- What type of activities does the GHRAVITY E.O. target?#185
- How do I know that a person has been designated under the GHRAVITY E.O.?#186
- Does the GHRAVITY E.O. prohibit me from exporting technology to companies that do business with Iran or Syria?#187
- If I am a non-U.S. company that exports information and communications technology to Iran or Syria, will I be designated under the GHRAVITY E.O.?#188
- Would I need authorization from OFAC or BIS if I wanted to export goods or technology to persons blocked under the GHRAVITY E.O.?#189
- Are existing licenses issued by the U.S. Government involving persons designated under the GHRAVITY E.O. still valid?#190
- What does Executive Order 13608 “Prohibiting Certain Transactions with and Suspending Entry into the United States of Foreign Sanctions Evaders with Respect to Iran and Syria” do?#191
- Why was this authority needed?#192
- What are the repercussions of an individual or entity being identified under Executive Order 13608?#193
- Are U.S. persons required to block the property of individuals and entities identified under Executive Order 13608?#194
- I am a financial institution. What do I do if I receive a wire transfer involving a listed party?#195
- I am a financial institution and I hold an account for a listed person. What do I do with the funds?#196
- What are U.S. persons obligated to do with property of a person listed under Executive Order 13608?#197
- May a U.S. person deal with an Executive Order 13608-listed person so long as the dealing does not involve Iran or Syria?#198
- How is an identification or listing under Executive Order 13608 different from a designation?#199
- How is this different from lists maintained by the Department of Commerce?#200
- May a U.S. person deal with a person listed under Executive Order 13608 in a transaction that was previously licensed by OFAC?#201
- What if the transaction is already underway?#202
- Can a U.S. person use a listed person to facilitate personal remittances to or from Iran or Syria?#203
- Will Treasury pursue an enforcement action before identifying or listing a person pursuant to Executive Order 13608?#204
- What were the criteria for Treasury's CISADA finding against Bank of Kunlun? How many other institutions were you looking at and why did you decide to take action against Bank of Kunlun?#207
- How are you defining “significant” transactions and financial services?#208
- What happens to the correspondent and payable-through accounts held by Bank of Kunlun in the United States?#209
- 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
- If a foreign financial institution continues to do business with Bank of Kunlun, could that lead to a CISADA finding against the other institution?#211
- Does this finding affect Bank of Kunlun's branches or subsidiaries around the world? Does this finding affect any holding companies?#212
- 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
- What is the licensing process for U.S. financial institutions that need to conduct transactions in order to close correspondent or payable-through accounts with a foreign financial institution sanctioned pursuant to the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA)?#214
- What is the difference, in practical effect, between this and a designation under one of your other authorities, like E.O. 13382?#215
- Isn’t the National Iranian Oil Company (NIOC) already subject to sanctions?#233
- What is the effect of the National Iranian Oil Company (NIOC) determination? Are there CISADA implications?#234
- What are the implications for petroleum purchase transactions involving NIOC by financial institutions and entities in countries that have received a significant reduction exception from the Secretary of State?#235
- Does the determination regarding the National Iranian Tanker Company (NITC) mean that there is no affiliation between NITC and the Iranian Revolutionary Guard Corps (IRGC)?#236
- How does the effect of this determination compare to the effect of section 1(a) of Executive Order 13622 as to transactions with National Iranian Oil Company (NIOC)?#237
- What are the major changes that the Iranian Transaction and Sanctions Regulations (ITSR) implement in superseding the Iranian Transaction Regulations (ITR)?#241
- The ITSR includes revisions to the ITR pertaining to the transfer of funds to or from Iran. Accordingly, how may I transfer funds to or from Iran that arise from, and are ordinarily incident and necessary to give effect to, an underlying transaction that is authorized under the ITSR?#242
- How can I send personal remittances to or from Iran under the Iranian Transaction and Sanctions Regulations (ITSR)?#243
- What effect will the Iranian Transaction and Sanctions Regulations (ITSR) have on Iranian-Americans and the people of Iran?#244
- What does the Statement of Licensing Procedure on Support of Human Rights-, Humanitarian-, and Democracy-Related Activities with Respect to Iran do?#245
- What does section 504 of the TRA do?#254
- Do the section 504 modifications of the TRA restrict any other dealings with Iran?#255
- What transactions are impacted by section 504 of the TRA as it amends section 1245 of the National Defense Authorization Act (NDAA) for Fiscal Year 2012?#256
- To which jurisdictions does the significant reduction exception apply (section 504 of the TRA)?#257
- What is meant by the TRA section 504’s requirement that bilateral trade consist of trade in goods and services between the country with primary jurisdiction over the foreign financial institution (FFI) and Iran?#258
- What can a foreign financial institution (FFI) do with the funds resulting from the import of Iranian-origin goods or services once the funds are credited to an account? Can funds be transferred to other accounts?#259
- What is a SPECIAL PURPOSE ACCOUNT for purposes of the National Defense Authorization Act's (NDAA) significant reduction exception?#260
- Are there any circumstances in which funds can be transferred to third-country financial institutions?#261
- Can funds be withdrawn from the RECIPIENT ACCOUNT or a SPECIAL PURPOSE ACCOUNT?#262
- Who can receive payments from funds credited to a RECIPIENT ACCOUNT or SPECIAL PURPOSE ACCOUNT?#263
- Can funds be remitted to Iran or the Government of Iran (GOI) without exposure to sanctions?#264
- Can the funds be used for sales made under the Humanitarian Exception?#265
- Does the November 8, 2012 designation of National Iranian Oil Company (NIOC) under E.O. 13382 impact the scope of permissible transactions by foreign financial institutions (FFIs) in significantly reducing countries?#266
- What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “food, medicine, and medical devices,” “foreign financial institution,” and “country with primary jurisdiction over the FFI”?#267
- How will the following Iran Freedom and Counter-Proliferation Act (IFCA) terms be interpreted: “Iran,” “knowingly,” “significant,” and “transfer”?#289
- Are payments or deliveries that are made on or after July 1, 2013, for contracts that existed prior to July 1, 2013, exempted from IFCA provisions?#290
- What are the implications of IFCA on the provision of humanitarian goods to the people of Iran?#292
- What will the “energy, shipping, and shipbuilding sectors of Iran” mean for the purposes of IFCA?#293
- How will I know if someone is part of Iran’s energy, shipping, or shipbuilding sectors or is a port operator in Iran?#294
- What are goods or services used in connection with Iran’s energy, shipping, or shipbuilding sectors for purposes of IFCA section 1244(d)(3)?#295
- Will the provision of bunkering services to a non-Iranian vessel carrying non-sanctionable goods to or from Iran be subject to sanctions?#296
- Are there any exceptions to the sanctions provisions of section 1244 of IFCA?#297
- For purposes of IFCA, what materials are considered graphite, raw or semi-finished metals?#298
- For purposes of IFCA, what are considered precious metals?#299
- For purposes of sanctions under section 1245, how will I know which sectors are controlled by Iran’s Islamic Revolutionary Guard Corps?#300
- How will the determination be made as to whether materials are used in a manner that would make them subject to sanctions under section 1245 of IFCA?#301
- Are there any exceptions to section 1245 of IFCA?#302
- Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under IFCA's section 1246(a)(1)?#303
- Are there exceptions to insuring, reinsuring, or underwriting sanctioned activities?#304
- What is the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA)?#313
- Can an exporter of agricultural commodities, food, medicine, or medical devices get paid out of a Central Bank of Iran (CBI) account at a foreign financial institution (FFI) in a country with a significant reduction exception, even though the exporter is located in a third-country? Can the third-country exporter’s bank handle this transaction?#314
- Will routine payments or fees be subject to sanctions if they are made to a person determined to be a port operator in Iran and if the vessel is carrying non-sanctioned goods?#315
- Does the GL for medical devices authorize the exportation or reexportation of all medical devices?#318
- Does the GL for medical devices authorize the exportation or reexportation of these items to all entities in Iran?#319
- How do I know whether a person is identified under E.O. 13608?#336
- Are transactions that were previously authorized under 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) prior to May 17, 2024 or General License (GL) D-2 still authorized under the revised 31 CFR § 560.540?#337
- With respect to the authorizations in 31 CFR § 560.540(a)(1) and (a)(2) of the Iranian Transactions and Sanctions Regulations (ITSR), what services and software are covered?#338
- With respect to the authorization in 31 CFR § 560.540(a)(3), do exporters need to make a determination as to whether an export of an item or service included in the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications is “incident to communications”?#339
- What should I do if I am unsure whether an item or service is covered by 31 CFR § 560.540?#340
- May a non-U.S. person export, reexport, or provide to Iran hardware or software that is subject to Commerce's Export Administration Regulations (EAR) pursuant to 31 CFR § 560.540?#341
- Does 31 CFR § 560.540 continue to authorize U.S. persons located outside the United States to export or reexport to Iran certain specified hardware or software that is not subject to Commerce's Export Administration Regulations (EAR)?#342
- Does 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) authorize the exportation to Iran and importation into the United States or a third country of communication devices by persons travelling to and from Iran?#343
- How can U.S. companies arrange for payment from Iran for exports authorized under 31 CFR § 560.540?#345
- What kind of due diligence is required for the exportation of fee-based services, software, or hardware authorized by 31 CFR § 560.540?#346
- Are there any restrictions as to the use of the Farsi language in authorized advertising or software?#347
- May U.S. persons employ agents in Iran to facilitate sales, create or fund a physical sales presence on the ground in Iran, or utilize Iranian commercial marketing services in furtherance of exports authorized under 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?#348
- What items and persons are excluded from the agricultural commodities general license in the Iranian Transactions and Sanctions Regulations (ITSR)?#361
- Is the exportation or reexportation of non-U.S.-origin agricultural commodities, medicine, or medical devices by a U.S. person to Iran authorized?#362
- Is the exportation or reexportation by non-U.S. persons of agricultural commodities, medicine, or medical devices that are subject to the Export Administration Regulations (EAR) to Iran authorized?#363
- Who can apply for a specific license if an export or reexport to Iran is not authorized by general license?#364
- What is authorized with respect to brokerage services related to exports or reexports of agricultural commodities, medicine, or medical devices to Iran?#365
- Do I still need to come in to OFAC for a specific license to export certain types of agricultural commodities to Iran?#366
- What is the definition of a “bioactive peptide”?#367
- Are payments or the facilitation of payments not involving U.S. persons to Iranian civil aviation authorities for overflights of Iran or landing in Iran by aircraft that are owned by a non-U.S. person and registered outside the United States sanctionable under U.S. law?#417
- Is the provision of routine goods and services by non-U.S. persons to diplomatic missions of the Government of Iran located outside the United States sanctionable under U.S. law?#455
- What key changes did the December 23, 2016 regulatory amendment to the Iranian Transactions and Sanctions Regulations (ITSR) make relating to the exportation and reexportation of agricultural commodities, medicine, and medical devices to Iran?#482
- How does an exporter determine which medical devices need to be specifically licensed by OFAC for exportation or reexportation to Iran?#483
- What types of training activities are considered to be necessary and ordinarily incident to the safe and effective use of medicine and medical devices?#484
- What key changes did the December 23, 2016 regulatory amendment to the Iranian Trade and Sanctions Regulations (ITSR) make to the definition of “Iranian-origin goods” or “goods of Iranian origin”?#485
- What is an example of goods otherwise coming into contact with Iran?#486
- Are goods that are unloaded from a ship in an Iranian port, put on a truck, and driven out of the boundaries of the port or place of unloading considered to be Iranian-origin goods?#487
- Are goods that are unloaded from a ship in an Iranian port, moved within the boundaries of the port, and loaded onto a second ship en route to a destination outside of Iran, without ever leaving the port considered to be Iranian-origin goods?#488
- What are the requirements of CAATSA section 105 related to the imposition of sanctions on the IRGC, and how are those requirements being implemented?#533
- Before October 13, 2017, wasn’t the IRGC already subject to sanctions? What’s different about applying terrorism-related sanctions to the IRGC and foreign persons that are officials, agents, or affiliates of the IRGC?#534
- In light of the recent earthquake in Iran, how can I help the Iranian people while making sure to abide by U.S. sanctions?#549
- What is the purpose of Executive Order (E.O) 13846 of August 6, 2018, “Reimposing Certain Sanctions With Respect to Iran”?#597
- What does E.O. 13846 do?#598
- When does E.O. 13846 become effective?#599
- Why does subsection 1(a)(iv) of E.O. 13846 take effect before November 5, 2018?#600
- Does E.O. 13846 expand the scope of sanctions that were in effect prior to January 16, 2016 (Implementation Day of the JCPOA)?#601
- Why does E.O. 13846 revoke E.O. 13716 and E.O. 13628?#602
- Do persons who were designated pursuant to E.O. 13628 of October 9, 2012, “Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Threat Reduction and Syria Human Rights Act of 2012 and Additional Sanctions With Respect to Iran,” continue to be subject to sanctions following the issuance of E.O. 13846?#603
- Why do the sanctions set out in E.O.s 13574 and 13590 not appear in E.O. 13846?#604
- How does E.O. 13846 relate to various Iran-related statutes?#605
- What activity will become sanctionable on or after August 7, 2018 under E.O. 13846 or other authorities?#606
- What activity will become sanctionable on or after November 5, 2018 under E.O. 13846 or other authorities?#607
- What transactions involving the Iranian rial are sanctionable under E.O. 13846?#608
- What does E.O. 13846 do with respect to the sanctions on Iran’s automotive sector?#609
- What is considered Iran’s automotive sector for purposes of E.O. 13846?#610
- What are goods or services used in connection with Iran’s automotive sector for purposes of E.O. 13846?#611
- Is the sale, supply, or transfer of finished vehicles or “auto kits” to Iran sanctionable under the New E.O.?#612
- Is the sale, supply, or transfer of goods or services for the maintenance of finished vehicles sanctionable under E.O. 13846?#613
- What does E.O. 13846 do with respect to Iran’s energy, petroleum, and petrochemical sectors?#614
- Does E.O. 13846 mean that Iran’s trade partners should no longer buy petroleum products from Iran? How will this affect exports of Iranian oil?#615
- Can countries that receive a significant reduction exception under NDAA 2012 purchase oil through NIOC and NICO without facing sanctions?#616
- E.O. 13846 targets transactions between foreign financial institutions and NIOC and NICO. What about a NIOC or NICO subsidiary? Are transactions with those entities also sanctionable under this E.O.?#617
- Does E.O. 13846 make sanctionable activities related to the pipeline project to supply natural gas from the Shah Deniz gas field in Azerbaijan to Europe and Turkey, given that NICO reportedly has a 10 percent stake in the project?#618
- Are barter arrangements or other non-cash trade transactions involving petroleum, petroleum products, or petrochemical products originating from Iran sanctionable under the terms of E.O. 13846?#619
- What are the definitions of "petroleum products" and "petrochemical products"?#620
- What is the prohibition on U.S.-owned or -controlled foreign entities, and how does it work?#621
- Are U.S.-owned or -controlled foreign entities covered under OFAC general licenses and/or permitted to apply for specific licenses from OFAC?#622
- Is there a wind-down or safe harbor provision for Section 8 of E.O. 13846?#623
- What are the implications of subsection 1(a)(iii) of E.O. 13846?#624
- Is the provision or delivery of goods or services to an Iranian counterparty after November 4, 2018 allowed?#630
- I was not able to receive payment for goods or services fully provided or delivered prior to the end of the wind-down period.How should I proceed?#631
- Will the U.S. government provide assurances beyond the guidance described in 631 and 634 that receipt of payment by non-U.S., non-Iranian persons is not sanctionable?#632
- Under what circumstances are goods or services considered “fully provided or delivered” prior to the expiration of the relevant wind-down period, as referenced in FAQ 631 above?#633
- Can I, as a non-U.S., non-Iranian person, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period pursuant to contracts entered into prior to May 8, 2018?#634
- Can I, as a U.S. person or U.S.-owned or -controlled foreign entity, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period under an OFAC wind-down authorization and pursuant to a contract entered into prior to May 8, 2018?#635
- Can I receive payment for activities undertaken during the wind-down period if the payment involves a person that has been added to the SDN List, including a person that was previously on the List of Persons Blocked Solely Pursuant to E.O. 13599 (the “E.O. 13599 List”) but is now designated under another authority?#636
- Is it sanctionable for non-U.S., non-Iranian persons to engage in transactions related to the provision of humanitarian and consumer goods to Iran?#637
- What happened to the E.O. 13599 List?#638
- Why are some persons that had been blocked solely pursuant to E.O. 13599 now designated pursuant to other authorities, such as E.O. 13224 and E.O. 13382?#639
- What does the November 5, 2018 amendment to the ITSR do?#640
- If a country with primary jurisdiction over a foreign financial institution did not receive a significant reduction exception (SRE) under section 1245(d)(4)(D) of the NDAA 2012, can funds currently held at the foreign financial institution in that country on behalf of the Central Bank of Iran be used to facilitate humanitarian trade with Iran?#641
- Is the provision of certain associated services relating to the purchase of petroleum or petroleum products from Iran by persons in a country that has been granted a SRE sanctionable?#642
- Is payment of Iran-related insurance or reinsurance claims made on or after November 5, 2018 sanctionable if the claim arises from an incident that occurred prior to November 5, 2018?#643
- Is an entity that is owned or controlled by a U.S. person and established or maintained outside the United States (a “U.S.-owned or -controlled foreign entity”) required to apply restrictions akin to blocking on the property or interests in property of persons subject to section 560.211 of the ITSR?#644
- How will the re-imposition of sanctions on November 5, 2018 impact the provision of specialized financial messaging services to Iranian financial institutions?#645
- What does E.O. 13871 do?#666
- When does E.O. 13871 become effective?#667
- Is there a wind-down period?#668
- Does E.O. 13871 expand upon existing sanctions relating to trade with Iran in certain raw and semi-finished metals, such as aluminum and steel?#669
- Are there exceptions to the sanctions imposed under E.O.13871?#670
- How are the terms “significant transaction or transactions; significant financial services; significant financial transaction” interpreted for purposes of correspondent or payable-through account sanctions set forth in section 2 of E.O. 13871?#671
- What does the August 06, 2019 regulatory amendment related to E.O. 13871 do?#682
- How is the term “significant transaction or transactions” interpreted for purposes of blocking sanctions set forth in section 1 of E.O. 13871?#683
- What is the definition of the “iron sector of Iran”?#684
- What is the definition of the “steel sector of Iran”?#685
- What are the definitions of “iron, iron products, steel, and steel products”?#686
- What is the definition of the “aluminum sector of Iran”?#687
- What are the definitions of “aluminum” and “aluminum products”?#688
- What is the definition of the “copper sector of Iran”?#689
- What are the definitions of “copper” and “copper products”?#690
- Will the provision of bunkering services to a non-Iranian vessel carrying sanctionable goods to or from Iran be subject to sanctions?#691
- Will the provision of bunkering services for an Iranian vessel be subject to sanctions?#692
- Do sanctions on COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. apply to its corporate parent and affiliates?#804
- Are non-U.S. persons exposed to sanctions for providing goods or services to, or engaging in other transactions with, a non-Iranian person sanctioned under section 3 of E.O. 13846?#805
- On December 11, 2019, the State Department announced that it would designate the Islamic Republic of Iran Shipping Lines (IRISL) and E-Sail Shipping Limited (“E-Sail”) under Executive Order (E.O.) 13382, effective June 8, 2020. IRISL and E-Sail are already listed on the SDN List. What will be the impact of the State Department’s designation of these entities under E.O. 13382?#810
- Can I ship agricultural commodities, food, medicine, and medical devices to Iran via IRISL or E-Sail on or after June 8, 2020?#811
- Is there a wind-down period for Executive Order 13902, “Imposing Sanctions with Respect to Additional Sectors of Iran” (E.O. 13902)?#816
- What does General License No. 8A (GL 8A) authorize with respect to humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC)?#821
- I'm a U.S. person that relied on general or specific licenses pursuant to 560.530, 560.532, or 560.533 of the ITSR to conduct humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) prior to their designations under E.O. 13224, as amended. Is any further authorization needed to conduct such transactions following the designations of the CBI and NIOC under E.O. 13224?#822
- Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions or activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) that U.S. persons would be authorized to engage in under General License No. 8A (GL 8A)?#823
- What is the Swiss Humanitarian Trade Arrangement (SHTA)?#824
- How can parties participate in the Swiss Humanitarian Trade Arrangement (SHTA) to export humanitarian goods to Iran?#825
- What options exist for exporting humanitarian goods to Iran outside the Swiss Humanitarian Trade Arrangement (SHTA)?#826
- I want to help with the humanitarian response to public health concerns, including the Coronavirus Disease 2019 (COVID-19) outbreak, in Iran. What can I do to help while remaining compliant with U.S. sanctions?#828
- Following the Secretary of State’s announcement on May 27, 2020 that he will be ending certain Iran nuclear-related waivers, will there be a wind-down period for persons engaged in activity permitted by these waivers?#829
- Will OFAC target Iranian manufacturers of medicines, medical devices, or products used for sanitation or hygiene or as personal protective equipment for use in Iran pursuant to Executive Order (E.O.) 13902 for continuing to manufacture these items? Will OFAC target persons conducting or facilitating transactions for the provision of such items to Iran if the transaction involves a person sanctioned under E.O. 13902?#830
- How will OFAC define the sectors of the Iranian economy specified in Executive Order (E.O.) 13902 of January 10, 2020?#831
- What are significant goods or services used in connection with a sector of the Iranian economy specified in Executive Order (E.O.) 13902?#832
- How will the terms “knowingly” and “significant” be interpreted for purposes of Executive Order (E.O.) 13902?#833
- What does General License L (GL L) authorize with respect to the financial sector of Iran and Iranian financial institutions (Iranian FIs) now sanctioned pursuant to Executive Order (E.O.) 13902?#842
- I'm a U.S. person that relied on general or specific licenses issued pursuant to the Iranian Transactions and Sanctions Regulations (ITSR) to conduct humanitarian-related or other transactions and activities prior to the identification of the financial sector of Iran and sanctioning of a number of Iranian financial institutions (Iranian FIs) under E.O. 13902. Is any further authorization needed to conduct such transactions following these actions?#843
- Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions, or other activities that would be authorized under the Iranian Transactions and Sanctions Regulations and General License (GL) L if engaged in by a U.S. person, involving Iranian financial institutions (Iranian FIs) sanctioned pursuant to E.O. 13902?#844
- Will there be a wind-down period for non-U.S. persons engaged in previously non-sanctionable activity involving the Iranian financial sector or Iranian financial institutions (FIs) that are now sanctioned pursuant to E.O. 13902?#845
- How do the sanctions imposed on the Iranian financial sector and Iranian financial institutions (FIs) pursuant to Executive Order (E.O.) 13902 affect waivers issued by the Department of State and exceptions set forth in the Iranian Freedom and Counter-proliferation Act of 2012 (IFCA)?#846
- As a result of the sanctions on the Iranian financial sector and certain Iranian financial institutions (Iranian FIs) pursuant to Executive Order (E.O.) 13902, do non-U.S. persons risk exposure to sanctions for continuing to engage in previously non-sanctionable trade involving the Iranian financial sector or E.O. 13902-sanctioned Iranian FIs, even after the end of the 45-day wind-down period?#847
- Can U.S. academic institutions provide online learning services to Iranian students located outside the United States? Can U.S. technology companies provide software and services to assist Iranian students in accessing online coursework?#853
- How will transactions related to official activities of international organizations be treated for purposes of secondary sanctions to the extent that the Iranian financial sector or Iranian financial institutions sanctioned under Executive Order (E.O.) 13902 are involved?#855
- How will transactions related to Iran’s participation in legal proceedings, including administrative, judicial, arbitral proceedings, and proceedings before international courts and tribunals, be treated for purposes of secondary sanctions to the extent that Iranian financial institutions or the Iranian financial sector sanctioned under Executive Order (E.O.) 13902 are involved?#856
- Do U.S. sanctions prohibit U.S. persons from visiting, or making donations to, the Imam Reza Holy Shrine in Mashhad, Iran?#932
- Does the general license at 31 CFR § 560.540 authorize the exportation of fee-based or no-cost cloud-based services and software to Iran that are used to support communications tools authorized by 31 CFR § 560.540?#1087
- What are OFAC’s due diligence expectations for cloud-based service or software providers whose services and software support communication tools are authorized by 31 CFR § 560.540?#1088
- Can persons seeking to export software, services, or hardware to Iran in support of internet freedom apply for a specific license from OFAC if the export is not authorized by 31 CFR § 560.540?#1089
- What are key changes made by the May 17, 2024, amendment to 31 CFR § 560.540 in comparison to Iran General License D-2?#1110
- Does General License (GL) O authorize all wind-down transactions for any vessel that was blocked on March 2, 2023? What if the vessel contains Iranian-origin merchandise?#1119
- Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions that U.S. persons would be authorized to engage in under Iran General License (GL) O?#1120
- What is the humanitarian channel in Qatar?#1134
- How can companies participate in the humanitarian channel in Qatar to export humanitarian goods to Iran?#1135
- Are "toll" payments to Iran for safe passage through the Strait of Hormuz authorized? Is receiving guarantees or services from Iran for or related to safe passage authorized, even when no payment is made?#1249
- Are Iranian digital asset exchanges blocked under OFAC sanctions?#1250
- Are non-U.S. persons exposed to sanctions for dealing with digital asset exchanges designated pursuant to Executive Order 13902, "Imposing Sanctions with Respect to Additional Sectors of Iran" (E.O. 13902)?#1257
Russian Harmful Foreign Activities Sanctions
- What does Executive Order (E.O.) 14024, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation” do?#886
- Are persons identified pursuant to Executive Order (E.O.) 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy blocked pursuant to E.O. 14024?#887
- What does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) do?#888
- Does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) prohibit participation in the secondary market for bonds issued by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation?#889
- Prior to June 14, 2021, are U.S. financial institutions prohibited from participating in the primary market for ruble or non-ruble denominated bonds issued by, or lending ruble or non-ruble denominated funds to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation?#890
- Does the 50 Percent Rule apply to Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive)?#891
- What does Russia-related General License (GL) 1B authorize?#894
- What is the purpose of Executive Order (E.O.) of August 20, 2021, “Blocking Property with Respect to Certain Russian Energy Export Pipelines”?#921
- How does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) change prohibitions relating to U.S. financial institution dealings in Russian sovereign debt pursuant to Directive 1 under E.O. 14024 of April 15, 2021?#965
- What actions did Treasury take in February 2022 related to Russia's financial services sector pursuant to Executive Order (E.O.) 14024?#966
- What does Directive 2 under Executive Order (E.O.) 14024, "Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions" (Russia-related CAPTA Directive) prohibit?#967
- What foreign financial institutions are listed in Annex 1 to Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?#968
- Does OFAC’s 50 Percent Rule apply to foreign financial institutions listed in Annex 1 to Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?#969
- Are foreign financial institutions (FFIs) located outside of Russia potentially subject to the prohibitions of Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?#970
- Are the prohibitions of Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive) limited to transactions denominated in U.S. dollars?#971
- Do non-U.S. financial institutions have to comply with the prohibitions of Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?#972
- I am a U.S. individual or company that maintains an account at a foreign financial institution sanctioned pursuant to Directive 2 under Executive Order (E.O.) 14024. What are my obligations?#973
- What Russian financial institutions were blocked in February 2022 pursuant to Executive Order (E.O.) 14024, and what activities are prohibited as a result?#974
- Is there a wind-down period for transactions involving the Russian financial institutions blocked in February 2022 pursuant to Executive Order (E.O.) 14024? What transactions are authorized during the wind-down period?#975
- What are transactions "related to energy" for purposes of Russia-related General License (GL) 8L?#977
- For transactions authorized under Russia-related General Licenses (GL) 6D, 7A, 115D, or 132, what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024?#978
- I am a U.S. person. Can I rely on a person sanctioned pursuant to Executive Order (E.O.) 14024 in connection with transactions for official business of an international organization, certain humanitarian-related trade, or the response to the Coronavirus Disease 2019 (COVID-19) pandemic?#979
- Do non-U.S. persons risk being sanctioned for engaging in activity with persons sanctioned pursuant to Executive Order (E.O.) 14024?#980
- What does General License (GL) 9A authorize with respect to the debt and equity of certain Russian financial institutions sanctioned pursuant to Executive Order (E.O.) 14024? What are the implications for U.S. and non-U.S. persons?#981
- Are U.S. funds allowed to buy or sell debt or equity of blocked Russian financial institutions? Are U.S. investors allowed to invest in a fund that holds debt or equity of a blocked Russian financial institution?#982
- What actions did the Office of Foreign Assets Control (OFAC) take in February 2022 with respect to new debt or equity restrictions pursuant to Executive Order (E.O.) 14024?#983
- What does 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?#984
- Does the 50 Percent Rule apply to Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive)?#985
- What constitutes debt or equity for purposes of Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive)?#986
- If a U.S. person entered into a revolving credit facility or long-term loan agreement for an entity determined to be subject to 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) prior to the relevant sanctions effective date described in the Russia-related Entities Directive, what are the restrictions on drawdowns from that facility? Do all drawdowns and disbursements pursuant to the parent agreement need to carry repayment terms of 14 days or less?#987
- 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?#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 dealings related to debt or equity issued before the relevant sanctions effective date by entities subject to it?#989
- May a debit to an account of a person blocked pursuant to Executive Order (E.O.) 14024 be authorized as a transaction that is ordinarily incident and necessary to a licensed transaction?#990
- 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)?#998
- What authorizations exist for entities subject to 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)?#999
- What sanctions are applicable to the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation?#1000
- Does the 50 Percent Rule apply to 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)?#1001
- Can U.S. persons engage in indirect transactions with persons subject to 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)?#1002
- Are transactions where the Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation serves solely as the operator of a clearing and settlement system authorized?#1003
- Are U.S. persons required to block transactions involving entities subject to 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)?#1004
- Does 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), prohibit trading in the secondary markets for Russian sovereign debt?#1005
- My company transports Russian oil for sale to the United States and third countries. Can I continue to transport or sell Russian-origin oil without violating sanctions pursuant to Executive Order (E.O.) 14024?#1010
- My U.S. bank refused to process a requested payment related to energy despite the authorization in Russia-related General License (GL) 115D under Executive Order (E.O.) 14024. What can I do?#1011
- Do I have to wind down energy-related transactions by the expiration date of Russia-related General License (GL) 8L?#1012
- What does Executive Order (E.O.) of March 8, 2022, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine,” do?#1013
- Are all energy imports from Russia now prohibited by Executive Order (E.O.) of March 8, 2022, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine”?#1014
- Is there a period for U.S. persons to continue imports prohibited by Executive Order (E.O.) of March 8, 2022, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine”?#1015
- I have a shipment of a product or products listed in Executive Order (E.O.) of March 8, 2022, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine,” en route to the United States that was contracted prior to March 8, 2022. Can I find a new buyer for this shipment, re-direct the shipment to a country other than the United States, or import the product and comply with the import ban?#1016
- Does Russia-related General License (GL) 8L remain valid following the issuance of Executive Order (E.O.) 14066, "Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine"?#1017
- Are non-U.S. persons exposed to sanctions if they continue to import to non-U.S. jurisdictions certain products of Russian Federation origin that are banned from the United States pursuant to Executive Order (E.O.) of March 8, 2022, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine”?#1018
- For the purposes of Executive Order (E.O.) 14066, 14068, as amended by E.O. 14114, 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 what is meant by the term “Russian Federation origin”?#1019
- Does Executive Order (E.O.) 14066 prohibit dealing in Kazakh-origin crude oil of the Caspian Pipeline Consortium (“CPC”)?#1020
- Do the prohibitions of Executive Order (E.O.) 14024 and other Russia-related sanctions extend to virtual currency?#1021
- What does Executive Order (E.O.) 14068, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” do?#1022
- I have a shipment of a certain product(s) listed in Executive Order (E.O.) 14068 en route to the United States that were contracted prior to March 11, 2022. Can I find a new buyer for this shipment, re-direct the shipment to a country other than the United States, or import the product(s) and comply with the import ban?#1024
- Executive Order (E.O.) 14068, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression” prohibits the importation into the United States of fish, seafood, and preparations thereof of Russian Federation origin. How does this affect Russia-related General License (GL) 6C?#1025
- Are non-U.S. persons exposed to sanctions if they continue to import to non-U.S. jurisdictions certain products of Russian Federation origin that are banned from the United States pursuant to Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression”?#1026
- For the purposes of Executive Order (E.O.) 14068, as amended, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” and associated determinations, what is meant by the terms “Russian Federation origin,” “fish, seafood, and preparations thereof,” “alcoholic beverages,” “unsorted diamonds,” and “non-industrial diamonds”?#1027
- Does the U.S. dollar-denominated banknote export ban imposed by Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” prohibit sending noncommercial, personal remittances denominated in U.S. dollars to the Russia Federation (or to individuals ordinarily resident in the Russia Federation)?#1028
- How do the prohibitions of Executive Order (E.O.) 14024 and other Russia-related sanctions impact gold-related transactions or persons participating in the gold market?#1029
- What obligations do operators of credit card systems have under the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. part 587 (RuHSR), and the Belarus Sanctions Regulations, 31 C.F.R. part 548 (BSR), with regard to payment cards issued by sanctioned Russian financial institutions?#1030
- What actions were taken on May 8, 2022 related to certain accounting, trust and corporate formation, and management consulting services?#1033
- For the purposes of the determination of May 8, 2022 made pursuant to Executive Order (E.O.) 14071, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” what is meant by the terms “accounting,” “trust and corporate formation,” and “management consulting” services?#1034
- For the purposes of Russia-related General License 35 what is meant by the terms “credit rating services” and “auditing services?”#1035
- When do the prohibitions imposed by the determination of May 8, 2022 made pursuant to Executive Order (E.O.) 14071, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” take effect?#1036
- For the purposes of the determination of May 8, 2022 made pursuant to Executive Order (E.O.) 14024, what is meant by the terms “accounting,” “trust and corporate formation services,” and “management consulting” sectors of the Russian Federation economy?#1038
- Are transactions ordinarily incident and necessary to the exportation or reexportation of agricultural commodities to, from, or transiting the Russian Federation that involve Agropromyshlennyi Kompleks Voronezhskii OOO, Anninskii Elevator OOO, and Azovskaya Zernovaya Kompaniya OOO authorized under OFAC sanctions?#1039
- Are transactions related to telecommunications and certain internet-based communications that involve persons designated pursuant to Executive Order 14024 authorized by Russia-related General License (GL) 25G?#1040
- For the purposes of Russia-related Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”), what is meant by the term “new investment”?#1049
- What types of transactions are considered to be “maintenance” activities described in FAQ 1049 and therefore outside the scope of the “new investment” prohibitions of Russia-related Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”)?#1050
- 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
- Can U.S. persons continue to fund their subsidiaries and affiliates with projects or operations located in the Russian Federation prior to the effective dates of the new investment prohibitions of Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”)?#1052
- Under the new investment prohibitions of Russia-related Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”), are transactions related to divestment in a project or operation in the Russian Federation permissible?#1053
- Do the new investment prohibitions of Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”) prohibit U.S. persons from purchasing debt or equity securities issued by an entity in the Russian Federation?#1054
- Do the new investment prohibitions of Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”) prohibit U.S. persons from lending funds to, or purchasing a debt or equity interest in, entities located outside of the Russian Federation?#1055
- For the purposes of section 1(a)(ii) of Executive Order (E.O.) 14071, what is meant by the term “person located in the Russian Federation”?#1058
- Do the determinations made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” on September 15, 2022, “Prohibitions Related to Certain Quantum Computing Services,” and on May 19, 2023, “Prohibitions Related to Architecture and Engineering Services” (“the determinations”), prohibit U.S. persons from providing services to persons located outside of the Russian Federation that are owned or controlled by persons located in the Russian Federation?#1059
- Does the determination made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services” (“the determination”), prohibit U.S. persons from serving as directors of companies located in the Russian Federation?#1060
- Do the determinations made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services, on September 15, 2022, “Prohibitions Related to Certain Quantum Computing Services,” and on May 19, 2023, “Prohibitions Related to Architecture and Engineering Services” (“the determinations”) prohibit U.S. persons from working as employees of entities located in the Russian Federation?#1061
- Do the prohibitions imposed by the determinations made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” on September 15, 2022, “Prohibitions Related to Certain Quantum Computing Services,” and on May 19, 2023, “Prohibitions Related to Architecture and Engineering Services,” apply to services provided to a parent company located in the Russian Federation by a U.S. subsidiary?#1062
- Do the prohibitions imposed by the determination made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services” (“the determination”), apply only with respect to the formation of new trusts and companies or do the prohibitions also apply with respect to existing trusts and companies?#1063
- Are executive search and vetting services included in the prohibition on management consulting services imposed by the determination made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services”?#1064
- Do the prohibitions imposed by the determination made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” prohibit U.S. persons from serving as voting trustees on behalf of, or for shares of, persons located in the Russian Federation?#1065
- Do the prohibitions imposed by the determination made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” prohibit the provision of educational services, such as online university courses, on the subjects of accounting, management consulting, or trust and corporate formation to persons located in the Russian Federation?#1066
- For the purposes of the determination made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services” (“the determination”), do accounting services include tax preparation and filing?#1068
- What does the gold-related determination pursuant to Executive Order (E.O.) 14068 prohibit?#1070
- Can I wind down financial contracts that may involve transactions prohibited pursuant to section (1)(a)(i) of Executive Order (E.O.) 14071 related to the purchase or receipt of debt or equity securities issued by an entity in the Russian Federation?#1071
- What does Russia-related General License (GL) 46 authorize with respect to credit derivative transactions referencing “the Russian Federation”?#1072
- Is Sheremetyevo International Airport blocked as a result of the designation of Alexander Anatolevich Ponomarenko?#1073
- Is EuroChem Group AG blocked as a result of the designation of Andrey Igorevich Melnichenko?#1074
- Is PhosAgro PJSC blocked as a result of the designation of Andrey Grigoryevich Guryev and Andrey Andreevich Guryev?#1075
- I am a U.S. person with an account at a Russian financial institution blocked pursuant to Executive Order (E.O.) 14024. What am I required or allowed to do under OFAC sanctions with respect to such accounts?#1080
- Am I required to show official documentation that I’ve closed my account at a Russian financial institution blocked pursuant to Executive Order (E.O.) 14024 in order to take advantage of Russia-related General License (GL) 50?#1081
- What actions were taken on September 15, 2022 related to certain quantum computing services?#1083
- For the purposes of the determination of September 15, 2022 made pursuant to Executive Order (E.O.) 14071, “Prohibitions Related to Certain Quantum Computing Services” (“the determination”), what is meant by the term “quantum computing services”?#1084
- For the purposes of the determination of September 15, 2022 made pursuant to Executive Order (E.O.) 14024, what is meant by the term “quantum computing sector of the Russian Federation economy”?#1086
- Do non-U.S. persons face sanctions risk for supporting Russia following its sham referenda, purported annexation, and continued occupation of the Kherson, Zaporizhzhya, Donetsk, and Luhansk regions of Ukraine?#1091
- Do non-U.S. companies risk exposure to sanctions for providing ammunition or other military goods to Russia or for supporting Russia’s military-industrial complex?#1092
- Is crude oil of Russian Federation origin that is loaded onto a vessel at the port of loading for maritime transport prior to December 5, 2022 subject to the price cap?#1094
- Do U.S. sanctions prohibit U.S. persons from engaging in transactions that are ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation located in or outside the United States?#1096
- 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
- Is Norilsk Nickel blocked as a result of the designation of Vladimir Potanin?#1104
- 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
- If a decedent’s estate includes securities issued by non-blocked Russian entities, do the new investment prohibitions in Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 prohibit the transfer of such securities, through inheritance, to the relevant beneficiary of the decedent’s estate?#1113
- What actions were taken on February 24, 2023 related to the metals and mining sector of the Russian Federation economy?#1114
- For the purposes of the determination of February 24, 2023 made pursuant to Executive Order (E.O.) 14024, what is meant by the term “metals and mining sector of the Russian Federation economy”?#1115
- Does the determination of February 24, 2023 made pursuant to Executive Order (E.O.) 14024 with regard to the metals and mining sector of the Russian Federation economy mean that all persons that operate or have operated in this sector of the Russian Federation economy are sanctioned by OFAC?#1116
- My company provides goods or services to, or engages in trade with, persons that operate or have operated in the metals and mining sector of the Russian Federation economy. Does my company risk being sanctioned by OFAC?#1117
- As of December 2022, the Government of the Russian Federation may require a so-called "exit tax" payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called "exit tax"? Does Russia-related [General License (GL) 13R](https://ofac.treasury.gov/media/936431/download?inline) authorize transactions that involve the payment of this exit tax?#1118
- Certain transactions related to telecommunications and certain internet-based communications are already authorized by Russia-related General License (GL) 25D. What additional transactions does Russia-related GL 65 authorize?#1122
- Under Executive Order (E.O.) 14024, "Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation," any person determined to operate or have operated in certain sectors of the Russian Federation economy may be blocked. How is OFAC defining those sectors?#1126
- What does a determination of a sector pursuant to Executive Order (E.O.) 14024 do?#1127
- Under Executive Order (E.O.) 14071, "Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation," U.S. persons are prohibited from providing certain services to persons located in the Russian Federation. How will OFAC define those categories of services?#1128
- Do blocking sanctions issued by the State Department on May 19, 2023 on Polimetall AO apply to its corporate parent and affiliates?#1129
- Is LETTERONE HOLDINGS S.A. (LetterOne) blocked as a result of the designation of Petr Olegovich Aven, Mikhail Maratovich Fridman, German Borisovich Khan, and Alexey Viktorovich Kuzmichev?#1131
- What does Executive Order (E.O.) 14114, “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities,” do?#1146
- How does Executive Order (E.O.) 14114 amend E.O. 14024, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation”?#1147
- What activities could expose a foreign financial institution (FFI) to sanctions under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?#1148
- What sanctions can be imposed on a foreign financial institution (FFI) that engaged in conduct described in section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114? What are the obligations of U.S. financial institutions?#1149
- 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
- How does OFAC intend to interpret the following terms in Executive Order (E.O.) 14024, as amended by E.O. 14114: “foreign financial institution,” “Russia’s military-industrial base,” and “significant transaction or transactions”?#1151
- Could foreign financial institutions (FFIs) that engage in transactions in non-USD currencies be sanctioned under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?#1152
- How does Executive Order (E.O.) 14114 of December 22, 2023 amend E.O. 14068, “Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression”?#1154
- What does the determination of December 22, 2023, “Prohibitions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof,” pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114 of December 22, 2023, (Seafood Determination) prohibit?#1155
- I have a shipment of a certain product(s) containing the types of seafood listed in the determination of December 22, 2023 pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114 of December 22, 2023, (Seafood Determination) en route to the United States that was contracted prior to December 22, 2023. Can I complete such import into the United States? Can I find a new buyer for this shipment and/or re-direct the shipment to a country other than the United States?#1156
- For the purposes of the determination of December 22, 2023 pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114 of December 22, 2023, (Seafood Determination) what is meant by the terms “salmon,” “cod,” “pollock,” and “crab”?#1157
- What prohibitions has OFAC implemented with respect to diamonds and diamond jewelry under the Russian Harmful Foreign Activities Sanctions program?#1164
- What does the determination “Prohibitions Related to Imports of Certain Categories of Diamonds” pursuant to Executive Order (E.O.) 14068 (the “Diamonds Determination”), prohibit?#1165
- What does the determination "Prohibitions Related to Imports of Diamond Jewelry and Unsorted Diamonds of Russian Federation Origin and Diamond Jewelry and Unsorted Diamonds Exported From the Russian Federation" pursuant to Executive Order (E.O.) 14068 (the "Diamond Jewelry and Unsorted Diamonds Determination"), prohibit?#1166
- What action did Treasury take on April 12, 2024 with regards to aluminum, copper, and nickel of Russian Federation origin?#1168
- What is prohibited by the determination [“Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin”](https://ofac.treasury.gov/media/932801/download?inline) pursuant to Executive Order (E.O.) 14071 (the “Metals Services Determination”)?#1169
- For the purposes of the determination [“Prohibitions Related to Imports of Aluminum, Copper, and Nickel of Russian Federation Origin”](https://ofac.treasury.gov/media/932796/download?inline) 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”](https://ofac.treasury.gov/media/932801/download?inline) pursuant to Executive Order (E.O.) 14071 (the “Metals Services Determination”), what is meant by the terms “aluminum,” “nickel,” and “copper”?#1170
- Do the determinations [“Prohibitions Related to Imports of Aluminum, Copper, and Nickel of Russian Federation Origin”](https://ofac.treasury.gov/media/932796/download?inline) 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”](https://ofac.treasury.gov/media/932801/download?inline) 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
- Does the determination [“Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin”](https://ofac.treasury.gov/media/932801/download?inline) 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
- Effective June 12, 2024, how is Treasury interpreting Russia’s military-industrial base under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?#1181
- Are foreign financial institutions (FFIs) subject to sanctions risk for providing all financial services involving persons blocked pursuant to Executive Order (E.O.) 14024, as amended? What about agricultural, medical, and other transactions authorized by OFAC General Licenses?#1182
- What action did Treasury take on June 12, 2024 with regards to prohibiting certain information technology (IT) and software-related services?#1184
- What activities are considered prohibited “information technology (IT) consultancy and design services” under the determination, “Prohibition on Certain Information Technology and Software Services,” pursuant to Executive Order (E.O. 14071) (the “IT and Software Services Determination”)?#1185
- What activities are considered prohibited “IT support services” and “cloud-based services” for enterprise management software and design and manufacturing software (collectively “Covered Software”) under the determination, “Prohibition on Certain Information Technology and Software Services”, pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”)?#1186
- How does OFAC intend to interpret the following terms in the determination, “Prohibition on Certain Information Technology and Software Services,” pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”): “enterprise management software,” “design and manufacturing software,” “cloud-based services,” “information technology support services,” and “information technology consultancy and design services”?#1187
- Does the determination, “Prohibition on Certain Information Technology and Software Services,” pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”) prohibit U.S. persons from providing services to persons located outside of the Russian Federation that are owned or controlled by persons located in the Russian Federation?#1188
- What additional authorizations did Treasury issue on August 23, 2024 with respect to certain diamonds and diamond jewelry prohibited by Executive Order (E.O.) 14068?#1189
- What is covered by the exclusions under 3(i) and 3(ii) related to the Export Administration Regulations (EAR) with respect to the IT and Software Services Determination?#1192
- I am a U.S. company with a subsidiary organized and located in Russia. Can I provide the employees or contractors of my Russian subsidiary who are located in Russia with the services prohibited by the Information Technology (IT) and Software Services Determination under the exclusion "(1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a U.S. person?#1193
- I am a U.S. company with a subsidiary located in a third country (other than Russia). My third-country subsidiary has an employee or contractor located in Russia. Can I provide that employee or contractor located in Russia with the services prohibited by the Information Technology (IT) and Software Services Determination under the exclusion "(1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a U.S. person"?#1194
- A U.S. company located in the United States has an employee or contractor located in Russia working directly for the U.S. company. Can the U.S. company provide that employee or contractor located in Russia with the services prohibited by the Information Technology (IT) and Software Services Determination under the exclusion "(1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a U.S. person"?#1195
- 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?#1197
- In light of the designation of Shreya Life Sciences Private Limited (Shreya), are U.S. persons authorized to engage in transactions related to pharmaceutical and other humanitarian-related goods involving Shreya and its subsidiaries?#1198
- What authorizations exist for diplomatic or consular missions operating in or outside of Russia and Russian diplomatic or consular missions operating abroad?#1201
- Following the November 21, 2024 designation of Russian financial institutions, Treasury has now designated a significant number of financial institutions in Russia. Will this negatively impact the processing of personal, non-commercial remittances to or from Russia?#1202
- What does [General License (GL) 115D](https://ofac.treasury.gov/media/935701/download?inline) ("Authorizing Certain Transactions Related to Civil Nuclear Energy") authorize with respect to civil nuclear energy-related payments?#1203
- 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?#1204
- For the purposes of the determination of January 10, 2025 made pursuant to Executive Order (E.O.) 14024 (the "January 2025 Energy Sector Determination"), what is meant by the term "energy sector of the Russian Federation economy"?#1213
- Does the determination of January 10, 2025, made pursuant to Executive Order (E.O.) 14024 (the "January 2025 Energy Sector Determination") mean that all persons that operate or have operated in this sector of the Russian Federation economy are sanctioned by OFAC?#1214
- Why did OFAC issue General License (GL) 26 ("Transactions Authorized Pursuant to the Russian Harmful Foreign Activities Sanctions Regulations") in the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589 (URSR)?#1215
- What action has Treasury taken with regard to the provision of petroleum services to Russia?#1216
- I am a U.S. service provider. Following the January 10, 2025 determinations under Executive Order (E.O.) 14024 and E.O. 14071 (the Energy Sector Determination and Petroleum Services Determination, respectively), am I still authorized to provide certain services relating to the maritime transport of Russian crude oil and Russian petroleum products to a non-sanctioned person operating in the energy sector of the Russian economy, so long as the crude oil or petroleum products are purchased at or below the price cap?#1217
- What negotiations does [Russia-related General License 131I](https://ofac.treasury.gov/media/936731/download?inline) authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?#1224
- What activities do [Russia-related General License 128C](https://ofac.treasury.gov/media/935496/download?inline) and [General License 131I](https://ofac.treasury.gov/media/936731/download?inline) authorize related to Lukoil International GmbH (LIG)?#1225
Cuba Sanctions
- What are the general travel authorizations in the Cuba program?#695
- Are authorized travelers who have initiated travel arrangements prior to the addition of an entity or subentity on the State Department’s Cuba Restricted List required to cancel their Cuba-related travel plans if their travel arrangements involve direct financial transactions with a listed entity or subentity?#696
- Do travelers who fall within the scope of a general license need to submit a written request to OFAC for permission to travel or conduct transactions?#697
- Is travel to Cuba for tourist activities permitted?#698
- What constitutes “a close relative” for generally authorized family travel?#699
- Who is generally authorized to engage in travel and travel-related transactions for “journalistic activity”?#700
- What constitutes generally authorized travel-related transactions for “professional research and professional meetings” in Cuba?#701
- What constitutes “educational activities” for generally authorized travel and other transactions?#702
- Are secondary schools and secondary school students permitted to engage in travel-related transactions under the general license for “educational activities”?#703
- Can travelers engage in “people-to-people travel” to Cuba on an individual basis or as a part of a group?#704
- Who is generally authorized to engage in travel-related transactions for “religious activities”?#705
- What constitutes generally authorized travel under the travel-related category of “public performances, clinics, workshops, athletic and other competitions, and exhibitions” ?#706
- What constitutes “support for the Cuban people” for generally authorized travel and other transactions?#707
- What constitutes “humanitarian projects” for generally authorized transactions, including travel-related transactions?#708
- What constitutes “activities of private foundations or research or educational institutes” for generally authorized travel?#709
- What constitutes “exportation, importation, or transmission of information or informational materials” for generally authorized travel?#710
- What are examples of a full-time schedule of activities for authorized travelers?#711
- Can I purchase a ticket to Cuba directly from an airline based or operating out of the United States?#712
- May a person that qualifies for the general license to provide carrier services transport a third-country national located in the United States to Cuba for travel authorized by a general license under one of the 12 categories of travel listed in Section 515.560 or by specific license from OFAC?#713
- May an individual authorized traveler take a commercial passenger ferry or use his or her private boat to travel to Cuba?#714
- Are U.S. vessels, including commercial passenger ferries or private boats, permitted to carry passengers to or from Cuba?#715
- Are authorized U.S. travelers permitted to travel onboard vessels in Cuba to meet their transportation needs within Cuba?#716
- Are there any spending limits for authorized U.S. travelers while in Cuba?#717
- Are there any CACR restrictions on what foreign persons entering the United States from travel that included Cuba may bring in their accompanied baggage?#718
- Can I purchase Cuban-origin cigars and/or Cuban-origin rum or other alcohol while traveling in Cuba?#719
- Can I purchase Cuban-origin cigars and/or Cuban-origin rum or other Cuban-origin alcohol while in a third country (i.e. not Cuba)?#720
- As an authorized traveler, may I travel from a third country to Cuba and from Cuba to a third country?#721
- May crew or other personnel involved in the operation of aircraft transporting authorized travelers to Cuba remain in Cuba along with the aircraft?#722
- Do air carriers or vessel operators need to obtain specific licenses from OFAC to provide services?#723
- Do travel service providers (such as travel agents and tour group operators) need to obtain specific licenses from OFAC to provide services for travel to Cuba?#724
- May persons subject to U.S. jurisdiction providing carrier services to authorized travelers between the United States and Cuba provide such services via a third country?#725
- In the case of a customer traveling to or from Cuba under a specific license, may providers of carrier and travel services collect and retain on file the specific license number in lieu of a physical or electronic copy of the license?#726
- Are carrier and travel service providers required to verify that an individual traveler is authorized to travel to Cuba?#727
- What types of arrangements may airlines enter into with a Cuban national (individual or entity) to facilitate the provision of carrier services between the United States and Cuba?#728
- Which individuals may be transported between the United States and Cuba by a person that qualifies for the general license to provide carrier services?#729
- What type of cargo may a person authorized to provide carrier services transport from the United States to Cuba?#730
- What type of cargo may a person authorized to provide carrier services transport from Cuba to the United States?#731
- What types of remittances are allowed to be made by persons subject to U.S. jurisdiction to persons in Cuba? What are the applicable conditions and requirements?#732
- Is a bank, credit union, or money services business (MSB) such as a money remitter permitted to process my authorized remittances to or from Cuba?#733
- What is the Cuba Restricted List and how does it impact Cuba-related transactions?#734
- What are examples of direct financial transactions with an entity or subentity on the State Department’s Cuba Restricted List prohibited by 31 CFR § 515.209?#735
- May the U.S. dollar be used to conduct transactions in Cuba or with Cuban nationals?#736
- Are authorized travelers permitted to open bank accounts in Cuba?#737
- Are authorized travelers in Cuba permitted to use credit or debit cards issued by a U.S. financial institution?#738
- Can my bank refuse to allow me to use my credit or debit card in Cuba?#739
- Can credit card network operators that are persons subject to U.S. jurisdiction process credit and debit card transactions for individuals traveling to, from, or within Cuba, and related settlements, for third-country financial institutions?#740
- Can U.S. financial institutions, including their foreign branches and foreign-incorporated subsidiaries, permit the use of credit and debit cards they issue by, and process credit and debit card transactions for, third-country nationals whose travel to, from, or within Cuba may not fall within the 12 categories of authorized travel?#741
- Are financial institutions other than banks permitted to open correspondent accounts in Cuba?#742
- Are Cuban banks permitted to open correspondent accounts at U.S. banks?#743
- May correspondent accounts authorized pursuant to 31 CFR § 515.584(a) or used for transactions authorized by 31 CFR § 515.584(g) be established and maintained in U.S. dollars?#744
- May U.S. banks open and operate accounts for Cuban nationals lawfully present in the United States?#745
- Can Cuban nationals lawfully present in a non-immigrant status or pursuant to another non-immigrant travel authorization issued by the U.S. government earn a salary?#746
- May U.S. banks, their foreign branches, and foreign subsidiaries open and operate accounts for Cuban nationals in third countries?#747
- May U.S. banks open and operate accounts for Cuban nationals present in Cuba?#748
- In what ways can Cuban nationals lawfully present in the United States participate in the U.S. financial system?#749
- If a Cuban national resident in the United States has applied to become a lawful permanent resident alien of the United States, does that individual have to apply to OFAC to be treated as an unblocked national?#750
- Should financial institutions apply for a specific license to unblock funds transfers or accounts which meet the conditions for unblocking set forth in 31 CFR §§ 515.505, or 515.584 (e)?#751
- Do U.S. banking institutions need to apply for a specific license to release funds transfers or accounts previously blocked pursuant to the CACR that are now authorized by general license?#752
- Is a financial institution required to independently verify that an individual’s travel is authorized when processing Cuba travel-related transactions?#753
- Is the U.S. originating bank or U.S. beneficiary bank required to independently verify that a person subject to U.S. jurisdiction is not engaging in a direct financial transaction as defined in § 515.209 when processing Cuba-related transactions?#754
- Is a U.S. or third-country financial institution required to independently verify that the underlying transactions giving rise to U.S. dollar monetary instruments presented for processing and payment pursuant to § 515.584(g) are authorized?#755
- May a person subject to U.S. jurisdiction utilize online payment platforms to facilitate or process authorized transactions involving Cuba or a Cuban entity?#756
- Are U.S. banking institutions authorized to process “U-turn” transactions in which Cuba or a Cuban national has an interest?#757
- Is Cuba open for U.S. business and investment?#758
- How do U.S. companies know if a Cuban counterpart is affiliated with an entity or subentity on the Cuba Restricted List?#760
- Can U.S. trade delegations travel to Cuba?#761
- May U.S. companies exporting authorized goods to Cuba assemble such goods in Cuba?#762
- If an authorized export to Cuba requires servicing or repair, may a person subject to U.S. jurisdiction import the item into the United States or a third country for such servicing or repair?#763
- Does 31 CFR § 515.533(a) authorize foreign subsidiaries of U.S. companies to export from a third country to Cuba foreign-manufactured items that are subject to the EAR?#764
- May persons subject to U.S. jurisdiction open an office in Cuba?#765
- What types of payment or financing terms may be utilized for authorized exports and reexports of items other than agricultural commodities to Cuba?#766
- What types of payment or financing terms may be utilized for authorized exports and reexports of agricultural commodities to Cuba?#767
- What does the regulatory term “cash in advance” mean?#768
- What types of Cuban-origin goods are authorized for importation directly into the United States?#769
- What types of goods and services produced by independent private sector entrepreneurs are authorized for importation into the United States from Cuba pursuant to 31 CFR § 515.582?#770
- May a person subject to U.S. jurisdiction provide training to a Cuban distributor or customer on the use of goods authorized for export to Cuba by the Department of Commerce?#771
- Are insurers that are persons subject to U.S. jurisdiction allowed to provide travel insurance to persons subject to U.S. jurisdiction engaged in authorized travel to Cuba?#772
- May persons subject to U.S. jurisdiction engaged in authorized travel to Cuba obtain travel insurance from a third-country vendor?#773
- May U.S. insurers issue policies and pay claims related to group health, life, and travel insurance on behalf of third-country nationals traveling to or within Cuba?#774
- May U.S. insurers, either directly or through third-country subsidiaries, issue policies, or pay insurance or reinsurance claims related to non-U.S. persons providing goods or services that facilitate travel by third-country nationals from a third country to Cuba?#775
- Are health, life, or travel insurance policies that are issued to a “group” (e.g., an employer and its employees) authorized by the CACR?#776
- May persons subject to U.S. jurisdiction provide certain insurance-related services (such as cargo or hull insurance, or reinsurance) to persons subject to U.S. jurisdiction who are engaging in authorized activity in Cuba?#777
- Does a person subject to U.S. jurisdiction require an OFAC specific license to pay an insurance claim that arises from authorized activity in Cuba if the payment involves a Cuban national?#778
- What are the “180-day rule” and the “goods/passengers-on-board rule”?#779
- Are there any exceptions to the 180-day rule and the goods/passengers-on-board rule?#780
- Do the exceptions to the 180-day rule authorize shipments to or from Cuba?#781
- If a foreign vessel is traveling to the United States via Cuba with cargo destined for the United States, may goods remain aboard the vessel for delivery to the United States while the vessel is docked in a Cuban port, and may that vessel and its cargo then enter the United States without being subject to the 180-day rule or the goods/passengers-on-board rule?#782
- May companies that use different ocean carriers as part of a broader shipping service utilizing code-sharing agreements take advantage of the exceptions to the “180-day rule”?#783
- What types of telecommunications services are authorized under general license?#784
- What types of internet-based services are authorized under general license?#785
- Is “peering” — an arrangement of traffic exchange between internet networks — authorized by the CACR?#786
- Are services related to caching, such as the provision of data storage systems that reduce internet network traffic, authorized by the CACR?#787
- What type(s) of business arrangements are telecommunications and internet-based service providers that are subject to U.S. jurisdiction authorized to establish in Cuba?#788
- May persons subject to U.S. jurisdiction who open an authorized business or physical presence, such as a joint venture, office, or retail outlet, in Cuba market their telecommunications or internet-based services?#789
- Are persons subject to U.S. jurisdiction engaging in authorized transactions permitted to enter into arrangements with Cuban state-owned entities, such as ETECSA?#790
- Are Cuban nationals located outside of Cuba still considered blocked?#791
- Can U.S.-owned or -controlled entities in third countries engage in trade/commerce with Cuban nationals located outside of Cuba?#792
- Are persons subject to U.S. jurisdiction authorized to provide financial services to Cuban nationals located outside of Cuba?#793
- What types of grants or awards in which Cuba or a Cuban national has an interest are authorized for persons subject to U.S. jurisdiction to provide?#794
- Can a grant authorized pursuant to the CACR be awarded to a Cuban state-owned entity?#795
- Are specific licenses still required for transactions relative to the administration of a Cuban estate?#796
- What types of projects would fall within the authorization in 31 CFR §515.575 for microfinancing projects?#797
- If a person had applied for a specific license from OFAC before the CACR was revised but now believes that the proposed activity is authorized pursuant to a general license, does that person need to wait for his or her specific license application to be adjudicated?#798
- Is a person subject to U.S. jurisdiction allowed to purchase or lease real property in Cuba?#799
- May persons subject to U.S. jurisdiction import Cuban-origin pharmaceuticals into the United States?#800
- May persons subject to U.S. jurisdiction provide services to Cuba or the Cuban government to support infrastructure maintenance and development in Cuba?#801
- May persons subject to U.S. jurisdiction provide mail or parcel delivery services to Cuba or Cuban nationals?#802
- What did the September 24, 2020 amendment to the Cuban Assets Control Regulations (CACR) do?#837
- What is the Cuba Prohibited Accommodations List and how do I know if I am authorized to lodge or pay for lodging at a property in Cuba?#838
- Are authorized travelers who have initiated travel arrangements prior to the addition of a property on the State Department’s Cuba Prohibited Accommodations List required to cancel their Cuba-related travel plans if their travel arrangements involve lodging at a listed property?#839
- What did the October 27, 2020 amendment to the Cuban Assets Control Regulations (CACR) do?#852
- What does the June 9, 2022 amendment to the Cuban Assets Control Regulations (CACR) do?#1056
- Are remittance forwarding service providers required to independently verify that a sender’s family or donative remittance is authorized when processing such remittances?#1057
- Can U.S. persons send remittances to Cuba using digital payments?#1090
- What level of due diligence are web hosting providers expected to conduct to ensure that a hosted website is not “for the promotion of tourism” pursuant to 31 CFR § 515.578?#1174
- Are services related to application programming interfaces (APIs) that are incident to the exchange of communications over the internet authorized for exportation or reexportation to Cuba pursuant to OFAC regulations?#1175
- What level of due diligence are internet-based service providers expected to conduct to determine whether the intended recipients of an export or reexport are prohibited officials of the Government of Cuba, prohibited members of the Cuban Communist Party, or organizations administered or controlled by the Government of Cuba or the Cuban Communist Party pursuant to 31 CFR § 515.578(b)(1)?#1176
- What internet-based services can be exported or reexported from the United States or by persons subject to U.S. jurisdiction to prohibited officials of the Government of Cuba, prohibited members of the Cuban Communist Party, or organizations administered or controlled by the Government of Cuba or the Cuban Communist Party?#1177
- Can a good be considered “produced by independent private sector entrepreneurs” for purposes of 31 CFR § 515.582 (authorizing the importation of certain goods and services produced by independent private sector entrepreneurs) if a Cuban state-owned entity is involved?#1178
- What type of small businesses are considered an “independent private sector entrepreneur” (as defined in 31 CFR § 515.340)?#1179
- What does [Executive Order (E.O.) 14404](https://ofac.treasury.gov/media/935581/download?inline) 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?#1251
- Does [E.O. 14404](https://ofac.treasury.gov/media/935581/download?inline) alter U.S. sanctions on Cuba pursuant to the Cuban Assets Control Regulations ([CACR](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515?toc=1))?#1252
- What does [Cuba-related General License (GL) 1](https://ofac.treasury.gov/media/935571/download?inline), "Transactions Authorized Pursuant to the Cuban Assets Control Regulations," authorize?#1253
- On May 7, 2026, the Department of State designated the Cuban entity Grupo de Administración Empresarial S.A. (GAESA) pursuant to [E.O. 14404](https://ofac.treasury.gov/media/935581/download?inline). Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with GAESA?#1254
- Are persons blocked pursuant to the Cuban Assets Control Regulations ([CACR](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515?toc=1)), 31 CFR part 515, automatically blocked pursuant to the [E.O. 14404](https://ofac.treasury.gov/media/935581/download?inline)?#1255
- Are all persons that operate or have operated in the five sectors of the Cuban economy identified in [E.O. 14404](https://ofac.treasury.gov/media/935581/download?inline) sanctioned by OFAC under E.O. 14404?#1256
- I am a non-U.S. person, what is my exposure to sanctions risk for transacting with entities owned by Grupo de Administración Empresarial S.A. (GAESA), the Cuban Ministry of the Interior (MININT), or the Cuban Ministry of the Revolutionary Armed Forces (MINFAR), including their subsidiaries listed on the [Cuba Restricted List (CRL)](https://www.state.gov/division-for-counter-threat-finance-and-sanctions/cuba-restricted-list)?#1258
- On July 13, 2026, the Department of State designated the Cuban entities Grupo Empresarial del Comercio Exterior (GECOMEX) and Grupo Empresarial de Transporte Marítimo Portuario (GEMAR) pursuant to [E.O. 14404](https://ofac.treasury.gov/media/935581/download?inline). Are non-U.S. persons, including foreign financial institutions (FFIs), exposed to sanctions risk for winding down transactions with GECOMEX or GEMAR?#1262
- I am a non-U.S. person engaged in humanitarian activities specifically looking to send food, medicine, or medical devices to Cuba. What is my exposure to sanctions under Executive Order (E.O.) 14404?#1264
- On August 20, 2026, the Department of State designated the Ministry of Construction of Cuba (MICONS) pursuant to E.O. 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with MICONS?#1265
- How does the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affect prohibitions related to the U.S. Department of State's [List of Restricted Entities and Subentities Associated with Cuba](https://www.state.gov/division-for-counter-threat-finance-and-sanctions/cuba-restricted-list) (Cuba Restricted List or CRL)?#1271
- How does the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affect those previously authorized "U-turn" transactions in which Cuba or a Cuban national has an interest?#1272
- How does the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affect previous authorizations related to Cuban private sector entrepreneurs?#1273
- How does the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affect educational travel to Cuba by persons subject to U.S. jurisdiction?#1274
- How does the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affect previous authorizations for professional meetings or conferences in Cuba?#1275
Venezuela Sanctions
- If an official of the Government of Venezuela is designated as a Specially Designated National (SDN), does that mean that the Government of Venezuela is blocked? What are the prohibitions on U.S. persons dealing with a designated government official?#505
- For purposes of Executive Order (E.O.) 13808 is Petroleos de Venezuela, S.A. (PdVSA) considered part of the Government of Venezuela?#507
- What do the prohibitions in Executive Order (E.O) .13808 mean? Are they blocking actions?#508
- Is there a wind-down or safe harbor provision for the prohibitions in Executive Order (E.O.) 13808?#509
- Has OFAC issued general licenses related to Executive Order (E.O.) 13808?#510
- For purposes of Executive Order (E.O.) 13808, what does OFAC interpret to be debt and equity? Can U.S. financial institutions continue to maintain correspondent accounts and process U.S. dollar-clearing transactions for the entities subject to these sanctions?#511
- Why is OFAC imposing sanctions and issuing general licenses specific to bonds and other securities?#512
- Do the prohibitions imposed pursuant to E.O. 13808 and subsequent Venezuela-related E.O.s also extend to entities owned 50 percent or more by the Government of Venezuela?#513
- If a U.S. person entered into a revolving credit facility or long-term loan arrangement for the Government of Venezuela prior to the sanctions effective date, what are the restrictions under E.O. 13808 on drawdowns from that facility? Do all drawdowns and disbursements pursuant to the parent agreement need to carry repayment terms of 90 days or less (for PdVSA) or 30 days or less (for the rest of the Government of Venezuela)?#514
- For purposes of Executive Order (E.O.) 13808 is the term "new equity" limited to equity that is issued by an entity owned or controlled by the Government of Venezuela after the sanctions effective date, or would equity purchased or acquired by an entity owned or controlled by the Government of Venezuela from a third party after the sanctions effective date be considered new equity?#515
- Does the prohibition in E.O. 13808 on "dealing in new debt" of longer than 90 days maturity (for PdVSA) or 30 days (for the rest of the Government of Venezuela) prohibit dealing in debt with maturity that exceeds the applicable authorized tenor in which the Government of Venezuela is not directly or indirectly the borrower?#516
- For the purposes of Executive Order (E.O. 13808) may a U.S. person consent to a replacement of its participation by a non-U.S. person in a long-term loan facility that was extended to the Government of Venezuela prior to the sanctions effective date?#517
- Is a U.S. person permitted under E.O. 13808 to extend credit for greater than 90 days (for PdVSA) or 30 days (for the rest of the Government of Venezuela) to a non-sanctioned party for the purpose of purchasing goods or services from the Government of Venezuela?#518
- How can I help the Venezuelan people while making sure to abide by the U.S. sanctions?#519
- Do I need a specific license from OFAC to send U.S.-origin food or medicine to Venezuela?#520
- I want to provide long-term financing to the Government of Venezuela to help with the exportation or reexportation of agricultural commodities, medicine, medical devices, components, or replacement parts and components for medical devices to Venezuela. Is that allowed?#521
- Other than through the existing general licenses, under what circumstances might U.S. persons be authorized to deal in new debt of greater than 30 or 90 days issued by the Government of Venezuela?#522
- The Venezuela Government International Bond issued on December 29, 2016 (ISIN USP97475AQ39, CUSIP AM1108092) is not included in the Annex to General License 3. Is that intentional? Did OFAC intentionally exclude any other bonds from the Annex?#523
- I would like to engage in derivatives transactions, including credit default swaps, related to a reference bond that is in the Annex to General License 3. Is that permitted?#524
- What does OFAC consider to be “profit” under Subsection 1(a)(iv) of E.O. 13808?#527
- Can U.S. Persons participate in meetings about restructuring outstanding Venezuelan and PDVSA debt?#547
- Subsection 1(a)(i) of E.O. 13808 prohibits U.S. persons from dealing in new debt with a maturity of greater than 90 days of PdVSA. For purposes of E.O. 13808, does the term “PdVSA” include all PdVSA subsidiaries?#548
- For purposes of E.O. 13808, what is “new debt”?#553
- For debt created on or after August 25, 2017, are U.S. persons permitted to accept payment from PdVSA or other segments of the Government of Venezuela if payment for a debt is not received within the applicable period specified in E.O. 13808 (90 days for PdVSA, 30 days for other segments of the Government of Venezuela)?#554
- For purposes of Executive Order (E.O.) 13827. Taking Additional Steps to Deal with the Situation in Venezuela" of March 19 2018, are the “petro” and “petro-gold” considered a “digital currency, digital coin, or digital token” that was issued by, for, or on behalf of the Government of Venezuela on or after January 9, 2018?#564
- For purposes of E.O. 13827 "Taking Additional Steps to Deal with the Situation in Venezuela" of March 19, 2018, is Venezuela’s traditional fiat currency, bolivar fuerte, considered a “digital currency, digital coin, or digital token” that was issued by, for, or on behalf of the Government of Venezuela on or after January 9, 2018?#565
- I participated in the pre-sale for a Government of Venezuela-issued “digital currency, digital coin, or digital token” before E.O. 13827 "Taking Additional Steps to Deal with the Situation in Venezuela" of March 19, 2018, became effective. Am I allowed to sell, trade, use, or otherwise deal in such “digital currency, digital coin, or digital token” on or after the sanctions effective date?#566
- What does [Venezuela-related General License 5Y](https://ofac.treasury.gov/media/936651/download?inline) authorize?#595
- Does E.O. 13835 prohibit me from attaching and executing against assets of the Government of Venezuela, including vessels, properties, or financial assets, if I have a legal judgment against the Government of Venezuela?#596
- What is the objective of Executive Order (E.O.) 13850 of November 1, 2018, "Blocking Property of Additional Persons Contributing to the Situation in Venezuela"?#628
- Executive order (E.O.) 13850 of November 1, 2018, “Blocking Property of Additional Persons Contributing to the Situation in Venezuela,” authorizes the imposition of sanctions on persons operating in Venezuela’s gold sector. For purposes of this E.O., how will OFAC target those who “operate in the gold sector of the Venezuela economy or any other sector of the Venezuela economy as may be determined by the Secretary of the Treasury in consultation with the Secretary of State”?#629
- What does Executive Order 13857 of January 25, 2019 "Taking Additional Steps to Address the National Emergency with Respect to Venezuela" do and how does this impact OFAC's Venezuela-related sanctions?#649
- What happened to the Petróleos de Venezuela, S.A. (PdVSA) bonds, or bonds issued by any entity directly or indirectly owned 50 percent or more by PdVSA, that were previously included in the Annex to General License 3?#651
- Is it permissible for mutual funds and exchange traded funds (collectively, “funds”) that are U.S. persons to buy, sell, or otherwise engage in transactions related to debt, equity, or other holdings in an entity that appears 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?#652
- 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?#653
- With regard to Venezuela-related General License 11, “Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with Petróleos de Venezuela, S.A.,” are U.S. financial institutions required to reject funds transfers involving both Petróleos de Venezuela, S.A. (PdVSA) or entities owned, directly or indirectly, 50 percent or more by PdVSA, and a non-U.S. entity located in a country other than the United States or Venezuela?#654
- Can U.S. persons in Venezuela purchase gasoline or other refined petroleum products from Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest?#656
- Can U.S. persons purchase, or engage in other transactions including swaps and non-cash transactions involving the purchase or exchange of, petroleum and petroleum products, if Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest is not directly involved in the transaction?#658
- Does Venezuela-related General License 12 authorize U.S. persons to export goods, services, and technology from the United States to Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest during the wind-down period?#659
- 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?#661
- What does General License 3I authorize with respect to Government of Venezuela debt, and what are the implications for U.S. and non-U.S. persons?#662
- Does the Secretary of the Treasury’s determination on March 22, 2019, that persons operating in the financial sector of the Venezuelan economy may be subject to sanctions pursuant to Executive Order 13850, as amended, mean that all Venezuelan financial institutions have been sanctioned by OFAC as of March 22, 2019, and are now blocked persons?#663
- Can U.S. financial institutions process transactions and maintain correspondent accounts in connection with activities authorized under Venezuela General Licenses 4A, 15, 16, 17, and 18?#664
- Will the designation of the Government of Venezuela restrict the ability of U.S. persons to support humanitarian efforts, including to engage in or facilitate the provision of humanitarian assistance or non-commercial, personal remittances to Venezuela?#665
- Executive Order (E.O.) 13884 of August 5, 2019, “Blocking Property of the Government of Venezuela,” blocks all property and interests in property of the Government of Venezuela. What does this mean for the IV Venezuelan National Assembly seated on January 5, 2016 (“IV National Assembly”)?#679
- Does the blocking of the Government of Venezuela impact the ability of U.S. persons to transact with the Government of Venezuela, or persons in which the Government of Venezuela owns, directly or indirectly, a 50 percent or greater interest?#680
- Does General License 28 extend the authorization of wind-down periods that have expired for Petroleos de Venezuela, S.A. (PdVSA), Banco Central de Venezuela (BCV), or other blocked Government of Venezuela persons?#681
- What types of activity does General License 35 authorize?#803
- Do I need a specific license from OFAC to file a suit in U.S. court against a person designated or blocked pursuant to Venezuela-related sanctions? Does a U.S. court, or its personnel, need a specific license from OFAC to hear such a case?#808
- What is the significance of OFAC’s designations of Rosneft Trading S.A. and TNK Trading International S.A.? Do the E.O. 13850 blocking sanctions on Rosneft Trading S.A. and TNK Trading International S.A. apply to their corporate parent and their affiliates?#817
- Is there a wind-down period for transactions involving Rosneft Trading S.A. or TNK Trading International S.A.?#818
- What does General License 37 authorize?#834
- What does General License 38 authorize?#854
- Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions and activities that would be authorized for U.S. persons pursuant to Venezuela General License (GL) 40C?#914
- For purposes of Venezuela General License (GL) 40C, what is liquefied petroleum gas?#915
- Are the authorizations in paragraph (a) of Venezuela-related General Licenses 7C and 20B, respectively, expired?#933
- In Crystallex Int’l Corp. v. Bolivarian Republic of Venezuela, 17-mc-00151 (D. Del.), the U.S. District Court for the District of Delaware has entered a Sale Procedures Order with respect to certain shares in PDV Holding (PDVH) to satisfy a U.S. district court judgment confirming an arbitral award against Venezuela. May persons participate in or comply with steps relating to a judicial sale of such shares?#1123
- I am a party seeking to enforce bondholder rights to the shares of CITGO Holding serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond, pending the outcome of ongoing litigation. How can I preserve or enforce my bondholder rights consistent with the Venezuela Sanctions Regulations, [31 CFR part 591](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-591/subpart-D/section-591.407) (VSR)?#1124
- I am a creditor of the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), or a PdVSA subsidiary. Do I need an OFAC license to negotiate the settlement of claims related to assets of the Government of Venezuela or PdVSA?#1125
- Can U.S. persons purchase bonds issued by the Government of Venezuela or Petróleos de Venezuela, S.A. (PdVSA) prior to August 25, 2017 on the secondary market?#1136
- For purposes of [General License (GL) 45B](https://ofac.treasury.gov/media/932686/download?inline), “Authorizing Certain Repatriation Transactions Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A.,” what countries are included in the “Western Hemisphere”?#1137
- Does Venezuela [General License (GL) 45B](https://ofac.treasury.gov/media/932686/download?inline) authorize U.S. persons to provide certain services, including refueling services, repair, and maintenance, to blocked Conviasa aircraft that are carrying out flights for the exclusive purpose of repatriating Venezuelan nationals from a third country in the Western Hemisphere to Venezuela?#1141
- How does [Venezuela General License (GL) 45B](https://ofac.treasury.gov/media/932686/download?inline) differ from Venezuela GL 45A?#1167
- How is Treasury planning to implement the President’s February 26 announcement on energy-related authorizations in Venezuela?#1218
- Does "Venezuelan-origin oil" as referenced in [Venezuela General License (GL) 46B](https://ofac.treasury.gov/media/935196/download?inline), "Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products," include petroleum products?#1226
- What activities does [Venezuela General License (GL) 46B](https://ofac.treasury.gov/media/935196/download?inline) authorize?#1227
- Does [Venezuela General License (GL) 46](https://ofac.treasury.gov/media/934886/download?inline), "Authorizing Certain Activities Involving Venezuelan-Origin Oil," authorize exploration activity or negotiations for new investment activities?#1228
- [Venezuela General License (GL) 46](https://ofac.treasury.gov/media/934886/download?inline) authorizes certain activity by an "established U.S. entity." What is an "established U.S. entity" for purposes of GL 46?#1229
- Can an entity that is not an "established U.S. entity" be involved in transactions authorized by [Venezuela General License (GL) 46](https://ofac.treasury.gov/media/934886/download?inline)?#1230
- What entities or jurisdictions are excluded from transactions authorized under [Venezuela General License (GL) 46](https://ofac.treasury.gov/media/934886/download?inline)?#1231
- What does OFAC consider "commercially reasonable terms," as described in [Venezuela General License (GL) 46](https://ofac.treasury.gov/media/934886/download?inline)?#1232
- Do the dispute resolution requirements in certain Venezuela General Licenses (e.g., [46D](https://ofac.treasury.gov/media/936806/download?inline), [47B](https://ofac.treasury.gov/media/936811/download?inline), [48B](https://ofac.treasury.gov/media/935671/download?inline), [50C](https://ofac.treasury.gov/media/936821/download?inline), [51C](https://ofac.treasury.gov/media/936826/download?inline), [52B](https://ofac.treasury.gov/media/936831/download?inline), [54B](https://ofac.treasury.gov/media/936836/download?inline), and [61A](https://ofac.treasury.gov/media/936841/download?inline)) apply to all contracts associated with an authorized transaction?#1233
- How does a financial institution verify a transaction is compliant with [Venezuela General License (GL) 46](https://ofac.treasury.gov/media/934886/download?inline)?#1234
- Does [Venezuela General License (GL) 46](https://ofac.treasury.gov/media/934886/download?inline) authorize downstream trading activities in Venezuelan-origin oil?#1235
- How does Venezuela [General License (GL) 30B](https://ofac.treasury.gov/media/934996/download?inline) differ from Venezuela GL 30A?#1236
- Do Venezuela General Licenses (GLs) [46A](https://ofac.treasury.gov/media/935001/download?inline) and [48](https://ofac.treasury.gov/media/934986/download?inline) allow for the payments of certain local taxes, permits, and fees in support of authorized transactions involving Venezuela’s oil or gas sectors?#1237
- Would OFAC approve the resale of Venezuelan origin oil to Cuba?#1238
- Where can I find the account information to make authorized payments to the Foreign Government Deposit Funds deposit account, as specified in Executive Order 14373?#1239
- For purposes of Venezuela [General License (GL) 47](https://ofac.treasury.gov/media/934891/download?inline) (Authorizing the Sale of U.S.-Origin Diluents to Venezuela), how does OFAC define diluent?#1240
- What does Venezuela [General License (GL) 48](https://ofac.treasury.gov/media/934986/download?inline) (Authorizing the Supply of Certain Items and Services to Venezuela) authorize?#1241
- What does Venezuela [General License (GL) 50A](https://ofac.treasury.gov/media/935031/download?inline) authorize?#1242
- What authorizations exist to develop oil or gas projects in Venezuela for companies that are not listed in Venezuela [General License (GL) 50A](https://ofac.treasury.gov/media/935031/download?inline) (Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities)?#1243
- How will OFAC assess specific license applications to perform any contingent contracts that are executed pursuant to Venezuela [General License (GL) 49](https://ofac.treasury.gov/media/935011/download?inline)?#1244
- What activities are authorized by [Venezuela General License (GL) 52](https://ofac.treasury.gov/media/935356/download?inline), "Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A."?#1245
- Does [General License 52](https://ofac.treasury.gov/media/935356/download?inline) authorize the sale of certain shares of CITGO that are the subject of Crystallex International Corporation v. Bolivarian Republic of Venezuela?#1246
- Do non-U.S. persons face sanctions risk for engaging in transactions authorized by General Licenses (GL) [46D](https://ofac.treasury.gov/media/936806/download?inline), [51D](https://ofac.treasury.gov/media/936856/download?inline), and [52B](https://ofac.treasury.gov/media/936831/download?inline)?#1247
- 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](https://ofac.treasury.gov/media/935201/download?inline) and [50A](https://ofac.treasury.gov/media/935031/download?inline), that include a reporting requirement. Which parties are responsible for providing such reports pursuant to those General Licenses?#1248
- Are private and commercial flights authorized to arrive in and depart from airports in Venezuela, and can they receive ground services in-country?#1259
- Does [General License (GL) 60](https://ofac.treasury.gov/media/936396/download?inline) require that payments to the Government of Venezuela be made into the Foreign Government Deposit Funds Account (FGDF)?#1263
- What activities does [Venezuela General License (GL) 61](https://ofac.treasury.gov/media/936736/download?inline) authorize?#1266
- Do certain Venezuela General Licenses (e.g., [46D](https://ofac.treasury.gov/media/936806/download?inline), [47B](https://ofac.treasury.gov/media/936811/download?inline), [48B](https://ofac.treasury.gov/media/935671/download?inline), [50C](https://ofac.treasury.gov/media/936821/download?inline), [51C](https://ofac.treasury.gov/media/936826/download?inline), [52B](https://ofac.treasury.gov/media/936831/download?inline), [54B](https://ofac.treasury.gov/media/936836/download?inline), and [61A](https://ofac.treasury.gov/media/936841/download?inline)) require a choice of law provision in contracts with the Government of Venezuela?#1267
- Do I need to include a dispute resolution provision in my contract with the Government of Venezuela to fall within certain Venezuela General Licenses (e.g., [46D](https://ofac.treasury.gov/media/936806/download?inline), [47B](https://ofac.treasury.gov/media/936811/download?inline), [48B](https://ofac.treasury.gov/media/935671/download?inline), [50C](https://ofac.treasury.gov/media/936821/download?inline), [51C](https://ofac.treasury.gov/media/936826/download?inline), [52B](https://ofac.treasury.gov/media/936831/download?inline), [54B](https://ofac.treasury.gov/media/936836/download?inline), and [61A](https://ofac.treasury.gov/media/936841/download?inline))?#1268
North Korea Sanctions
- What does Executive Order (E.O.) 13722 do?#456
- Does Executive Order (E.O.) 13722 take into account United Nations Security Council Resolution (UNSCR) 2270 and domestic legislation?#457
- Does the blocking of the Government of North Korea and the Workers’ Party of Korea impact the ability of U.S. persons to do business with or conduct transactions with entities in which either party has an interest?#458
- What impact does the prohibition on the exportation or reexportation of goods, services, or technology under Executive Order (E.O.) 13722, as implemented in § 510.205 of the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR), have on the regulations of the Department of Commerce’s Bureau of Industry and Security (BIS)?#459
- Can U.S. persons do business with entities in North Korea?#460
- Has OFAC issued general licenses for the North Korea program?#461
- Can U.S. persons continue to send money to family or friends in North Korea?#462
- Can nongovernmental organizations (NGOs) provide assistance to North Korea? If so, what types of assistance can NGOs provide? Can NGOs conduct transactions with the Government of North Korea?#463
- Can I travel to North Korea?#464
- What is an example of a person who forms part of the household of an employee of the official mission of the Government of North Korea or of an employee of the United Nations?#465
- What sanctions authority does Executive Order (E.O.) 13810 provide?#525
- How does the Secretary of the Treasury make a determination about funds blocked from certain foreign bank accounts pursuant to section 3 of Executive Order (E.O) 13810 and implemented in 31 C.F.R. § 510.201(d)? How are U.S. persons expected to know which funds are blocked?#526
- What activities by foreign financial institutions can subject them to sanctions under the revised North Korea Sanctions Regulations (NKSR) incorporating the provisions of Executive Order (E.O.) 13810?#555
- When are the prohibitions and strict conditions on foreign financial institutions’ correspondent accounts or payable-through accounts in the United States pursuant to Executive Order (E.O.) 13810 effective?#556
- How will U.S. and foreign financial institutions (FFIs) know that the Treasury Department has imposed prohibitions or strict conditions on FFIs’ correspondent accounts or payable-through accounts in the United States pursuant to § 510.210 of the North Korea Sanctions Regulations (NKSR)?#557
- Are news reporting organizations and journalists authorized to conduct activities in North Korea?#558
- What changes did the February 15, 2024 regulatory amendment to the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR), make?#1160
- Does the general license for non-governmental organization (NGO) activities at section 510.512 of the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR), authorize NGOs to engage in transactions involving the Government of North Korea?#1161
- What must a non-governmental organization (NGO) do before relying on the general license (GL) at § 510.512 of the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR)?#1162
- Can I export tobacco or other luxury goods to North Korea?#1163
Chinese Military Companies Sanctions
- Do the prohibitions in Executive Order (E.O.) 13959, as amended, apply to purchases or sales of publicly traded securities of subsidiaries of entities listed on the Non-SDN Chinese Military-Industrial Complex Companies List (the “NS-CMIC List”)#857
- What are “publicly traded securities” for purposes of Executive Order (E.O.) 13959, as amended?#859
- For purposes of Executive Order (E.O.) 13959, as amended, what financial instruments are covered by the provision stating the prohibitions apply to “any publicly traded securities that are derivative of such securities or are designed to provide investment exposure to such” publicly traded securities?#860
- Does Executive Order (E.O.) 13959, as amended, prohibit U.S. persons from investing in U.S. or foreign funds, such as exchange-traded funds (ETFs) or other mutual funds, that hold publicly traded securities of a Chinese Military-Industrial Complex Company (CMIC)?#861
- Can U.S. persons custody, offer for sale, serve as a transfer agent, and trade in covered securities?#863
- May market intermediaries and other participants facilitate divestment from publicly traded securities of Chinese Military-Industrial Complex Companies (CMICs), including divestment by investment fund managers?#865
- What are the compliance obligations of securities exchanges operated by U.S. persons with respect to Executive Order (E.O.) 13959, as amended?#871
- What is the effect of Executive Order (E.O.) of June 3, 2021, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People's Republic of China”?#898
- What entities are subject to Executive Order (E.O.) 13959, as amended, and when do the prohibitions against such entities go into effect?#899
- Executive Order (E.O.) 13959, as amended, authorizes the imposition of certain sanctions on persons who operate or have operated in the surveillance technology sector of the economy of the People’s Republic of China (PRC). For the purposes of E.O. 13959, as amended, how will OFAC target those who operate or have operated in this sector?#900
- Under Executive Order (E.O.) 13959, as amended, what level of due diligence must U.S. persons, including market intermediaries and other participants, undertake to assess whether an underlying purchase or sale is prohibited under E.O. 13959, as amended?#901
- Under Executive Order (E.O.) 13959, as amended, are U.S. persons prohibited from providing investment advisory, investment management, or similar services to a non-U.S. person, including a foreign entity or foreign fund, in connection with the non-U.S. person’s purchase or sale of covered securities of Chinese Military-Industrial Complex Companies (CMICs)?#902
- Do the prohibitions of Executive Order (E.O.) 13959, as amended, apply to U.S. persons who are employed by non-U.S. entities and who, in the ordinary course of their employment, are involved in purchases or sales of Chinese Military-Industrial Complex Companies’ (CMICs) securities on behalf of their non-U.S. employer?#903
- Under Executive Order (E.O.) 13959, as amended, are U.S. market makers permitted to facilitate divestment from publicly traded securities of Chinese Military-Industrial Complex Companies (CMICs)?#904
- Does Executive Order (E.O.) 13959, as amended, prohibit U.S. persons from engaging in all activities with companies listed on the Non-SDN Chinese Military-Industrial Complex Companies List (the "NS-CMIC List")?#905
- Are U.S. persons required to divest their current holdings of Chinese Military-Industrial Complex Companies' (CMIC) securities before the end of the relevant 365-day divestment period pursuant to section 1(c) of Executive Order (E.O.) 13959, as amended?#1046
- For the purposes of Executive Order (E.O.) 13959, as amended, can holders of Chinese Military-Industrial Complex Companies' (CMIC) securities receive stock splits, cash dividends, or dividend reinvestments related to the covered securities, and are U.S. financial institutions allowed to process transactions related to this activity?#1047
- After the relevant 365-day divestment period, are U.S. financial institutions required to block the attempted purchase or sale of Chinese Military-Industrial Complex Companies' (CMIC) securities covered by Executive Order (E.O.) 13959, as amended?#1048
Basic Information on OFAC and Sanctions
- What is OFAC and what does it do?#1
- What kinds of prohibitions does OFAC impose?#3
- Are there exceptions to sanctions prohibitions? Are exceptions the same across sanctions programs?#4
- Where can I find specific details about a particular sanctions program?#6
- If I want to engage in a transaction or activity prohibited by OFAC, how can I do so? Can I rely on a general or specific license to engage in a transaction involving a sanctioned jurisdiction or person?#7
- What does OFAC mean when it refers to "blocked" property? How does OFAC define “property”?#9
- What jurisdictions or countries are sanctioned by the United States?#10
- Who must comply with OFAC sanctions?#11
- How much are the penalties for violating OFAC sanctions regulations?#12
- I am aware of a possible violation of OFAC-administered sanctions. How can I report the possible violation to OFAC? Are there benefits to reporting this information to OFAC?#13
- Can I regard previously issued and published opinion letters, regulatory interpretations, or other statements as guidance for my transactions?#14
- Can OFAC change its previously stated, non-published interpretation or opinion without first giving public notice?#15
- What lists does OFAC maintain? Where can I find these lists?#91
- I tried to ship a package and it was either "blocked" by a shipping company or returned to me because of "OFAC sanctions." Why? How do I get my package back?#126
- How do I verify the authenticity of an OFAC document?#468
- Does OFAC issue certificates of non-inclusion, or issue a so-called "safe list" to help prove that an entity or individual is not on one of OFAC’s sanctions lists?#469
- Do U.S. sanctions target persons for engaging in political speech, religious practice, or other constitutionally protected activities?#1190
OFAC Licenses
- I believe OFAC may have blocked my funds. How can I get my funds released?#51
- Is OFAC likely to approve my license application? How long will it take?#58
- Do I need an OFAC license to donate goods to sanctioned jurisdictions?#59
- What is an OFAC license?#74
- How do I apply for an OFAC specific license?#75
- My specific license application was denied. Can I appeal OFAC's determination?#76
- How can I find the status of my pending specific license application?#77
- What agencies other than Treasury review OFAC specific license applications and what are the roles of these other agencies?#78
- What format options are permitted for submitting license applications pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA)?#97
- How should I present my TSRA license application?#98
- If I am submitting multiple TSRA license applications at the same time, should I send them under a single cover letter?#100
- Should I send a sample of the proposed export product as an attachment to my TSRA license application?#101
- Specific to Iran I hold a specific license to sell agricultural goods, medicine, or medical devices to Iran. The general license at section 560.532(a)(4) of the Iranian Transactions and Sanctions Regulations (ITSR) authorizes me to accept a letter of credit issued by an Iranian financial institution whose property and interests in property are blocked solely pursuant to the ITSR (i.e., an Iranian financial institution that is not listed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List)). The general license, however, also states that a U.S. financial institution may not advise, confirm, or otherwise deal in that credit. How am I supposed to know if/when a letter of credit has been issued for my sale and how do I get paid? My bank accounts are all at U.S. financial institutions.#117
- I am an exporter of agricultural commodities, medicine, or medical devices to Sudan and have previously obtained specific licenses from OFAC for such exports. Do I still need to apply for a specific license from OFAC for exports or reexports of such items to Sudan?#500
- How do I find the case identification ("Case ID") number for my license application? Is it different from the Reference ID or Application Alias in my original application?#1269
- How can I get my OFAC specific license amended or renewed?#1270
Compliance for Internet, Web Based Activities, and Personal Communications
- Can I send money to a sanctioned country using a third-country company’s website? Can I buy gifts for someone in a sanctioned country over the internet? The websites tell me that it’s ok because they themselves are not sanctioned parties.#72
- My company provides money remittance and account services via the Internet. Does OFAC have any compliance guidance for this type of business?#73
- Are all applications designed to run on mobile operating systems (“apps”) covered by 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?#434
- Is the exportation of anti-virus, anti-malware, anti-tracking, and anti-censorship software authorized under 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?#435
- What do Secure Socket Layers (SSLs), listed in the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications, encompass?#436
- Are mobile phone accessories and computer accessories and peripherals authorized for export under 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?#437
- Is the exportation of parts or components for authorized hardware, such as microprocessors, authorized under 31 CFR § 560.540?#438
- Does 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) authorize the export of bundled software that includes both software authorized by § 560.540 and software that is not authorized by § 560.540?#439
- 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) authorize the exportation to Iran of fee-based desktop publishing software and productivity software suites used to publish documents, presentations, spreadsheets, charts, music, movies, and digital images?#440
- Does 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) authorize the provision of fee-based cloud computing services to Iran?#441
- For purposes of category (5) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications, what would be considered “software required for effective consumer use” of personal computing devices, laptops, and tablets?#442
- What are "residential consumer" satellite terminals and transceiver equipment for the purposes of category (4) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications?#443
- What are “user authentication services” for purposes of the general license in [31 CFR § 560.540](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-560) of the Iranian Transactions and Sanctions Regulations (ITSR)?#1173
How to Search OFAC's Sanctions Lists
- Does OFAC have a web-based search engine for its sanctions lists?#82
- How does Sanctions List Search work?#246
- What does the Sanctions List Search Score mean?#247
- How do I use the Minimum Name Score field and score slider bar?#248
- How is the Score calculated?#249
- Does OFAC recommend a specific match threshold score?#250
- What fields influence the score?#251
- What fields use fuzzy logic?#252
- When conducting a search using the ID field, does Sanctions List Search account for variations in non-alphanumeric characters?#253
- Who may use Sanctions List Search? Can we configure our automated system to utilize Sanctions List Search on a continual basis?#287
- Does Sanctions List Search look for potential matches on all of the various sanctions lists that OFAC has published on its website?#369
- Does the Sanctions List Search tool show historic information? For example, does it show names that have been removed from one of OFAC's sanctions lists?#467
- What is the difference between the previous version of Sanctions List Search, and the upgraded version made live to the public on January 25, 2021?#892
Compliance for the Insurance Industry
- State insurance statutes regulate an insurer's ability to withhold claim payments, cancel policies, or decline to enter into policies. In some cases, insurers must commit an ostensible violation of state insurance regulations to comply with OFAC regulations. Do OFAC regulations preempt state insurance regulations in this context?#61
- What should an insurer do if an applicant for a policy, or the underlying insured activity, is subject to OFAC sanctions?#62
- What should an insurer do if it discovers that a policyholder or a named beneficiary is added to OFAC's Specially Designated Nationals and Blocked Persons List (SDN List) or located in a jurisdiction subject to sanctions?#63
- If an insurance policy is held by the employer on behalf of its employees, is it permissible for an insurer to maintain the policy if it covers a blocked person on OFAC's Specially Designated Nationals and Blocked Persons List (SDN List), since the insurer is transacting only with the employer and not with the blocked person?#64
- How frequently is an insurer expected to screen its databases for OFAC compliance?#65
- If a policyholder becomes a Specially Designated National (SDN) or blocked person after policy issuance, can the insurer notify the policyholder that the policy is now "blocked"?#68
- When notifying a policyholder that their policy is "blocked" due to OFAC sanctions, may the insurer also instruct the policyholder not to send further premium payments or that the insurer will not accept additional premium payments under this account?#69
- How can an insurer or reinsurer participate in worldwide insurance markets through global insurance policies if, by definition, coverage extends to potential risks in sanctioned countries?#102
- What if market circumstances of the relevant commercial setting do not permit the use of a U.S. sanctions-specific exclusionary clause?#103
- Can an insurer offer global travel insurance and worldwide travel assistance without violating U.S. sanctions?#104
- Can a claim be paid under a policy issued to a blocked individual or entity if the payment is to an innocent third-party (for example, the injured party in an automobile accident)?#1199
- If a non-sanctioned person files a claim with their insurance company for a loss caused by a blocked person, such as a designated terrorist organization, is the insurance company permitted to pay the claim?#1200
Additional Questions from Financial Institutions
- If my financial institution receives a wire going to an embassy in a sanctioned country, can we process the transaction?#40
- 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?#43
- Is there a dollar limit on which transactions are subject to OFAC regulations?#44
- Does my bank need to check the OFAC list when selling cashier's checks and money orders? In the case of cashier's checks, do I need to check both the purchaser and the payee? As a mortgage lender, do I need to check both the purchaser and the seller's name against the Specially Designated Nationals list? Do I need to check their names against all of OFAC's other sanctions lists?#45
- If a loan meets underwriting standards but is a true "hit" on OFAC's Specially Designated Nationals (SDN) list, what do we use as a denial reason on the adverse action notice?#46
- Through corporate giving programs, many banks contribute toward charities and other non-profits. To what extent does a bank need to review the recipients of these gifts or the principals of the charities?#47
- Can U.S. financial institutions open correspondent accounts for Iraqi financial institutions, or process funds transfers to and from Iraqi financial institutions?#52
- Does a financial institution have the obligation to screen account beneficiaries for compliance with OFAC regulations?#95
- On February 14, 2008, OFAC issued guidance stating that the property and interests in property of an entity are blocked if the entity is owned, directly or indirectly, 50% or more by a person whose property and interests in property are blocked pursuant to an Executive Order or regulations administered by OFAC. We act as an intermediary bank in wire transfers between other banks. Does OFAC expect banks that are acting as financial intermediaries to research non-account parties that do not appear on the SDN List, but are involved with or referenced in transactions that are processed on behalf of correspondents?#116
- Firms operating in the securities industry as custodians and securities intermediaries often face the question of how to accurately identify the beneficial owner of assets within an account or transaction. What can these firms do to protect themselves from the risk of directly or indirectly providing services to—or dealing in property in which there is an ownership or other interest of—parties subject to sanctions?#335
Blocking and Rejecting Transactions
- How do I block an account or a funds transfer?#32
- How much interest do I have to pay on the blocked funds?#33
- Can my bank deduct service charges from the account?#34
- Do all OFAC programs involve blocking transactions?#35
- I understand blocking a transaction, but what is meant by rejecting a transaction? When should a transaction be rejected rather than blocked?#36
- What do I do if I have a blocked account that needs to be escheated to the state?#39
- Should an institution tell its customer that it blocked their funds, and, if so, how does the institution explain it to them?#41
- What do I do if a person tries to open an account and the individual or entity’s name is on OFAC’s SDN List (or is otherwise a blocked person)? Do I open the account and then block the funds?#42
- I just received an interdiction "alert." What do I do?#48
- How do I differentiate between an "inquiry" and a "payment instruction" when a customer wants to send a wire transfer to a sanctioned party or country?#53
Information on List File Formats and Downloads
- Does OFAC provide its Specially Designated Nationals (SDN) List in a format that can be easily imported into a database?#79
- Does OFAC provide its Specially Designated Nationals (SDN) List in a spreadsheet format?#80
- What is the delimiter in OFAC's delimited files?#81
- How are OFAC's delimited files structured?#83
- I am a developer looking to design an automated process that will download OFAC's Specially Designated Nationals (SDN) list and other sanctions lists without human intervention. How can I do this given that changes to the sanctions lists can be sporadic?#88
- I am a database administrator at a financial institution and am responsible for keeping my company's sanctions list data current. Are OFAC's sanctions lists comprehensive or do I need to download some kind of supplement to the list every time there is an update?#89
- Do you offer a Specially Designated Nationals (SDN) changes file or "delta file" in a data format? Do you offer delta files for OFAC's other sanctions lists?#90
- OFAC says it has updated one or more of its sanctions lists, but when I download the appropriate data files from the OFAC website, they appear to be out-of-date. Where can I get the latest SDN information?#105
- How do I get a copy of one or more of OFAC’s other sanctions lists (in addition to the Specially Designated Nationals list)?#422
- What is a UID? And why does OFAC sometimes publish lists of UIDs in its Recent Actions notices?#1031
Cross-Programmatic Compliance Services Guidance
- Why did OFAC issue the Guidance on the Provision of Certain Services Relating to the Requirements of U.S. Sanctions Laws (the “Compliance Services Guidance”)?#495
- Does the Compliance Services Guidance represent a change in OFAC’s policy with respect to the provision of legal and compliance services?#496
- In providing services consistent with the Compliance Services Guidance to a foreign covered person, can a U.S. person opine on the legality of a transaction under U.S. sanctions laws, including by providing a legal opinion, certification, or other clearance as to the legality of such transaction, where it would be prohibited for a U.S. person to engage in such transaction?#497
- The Compliance Services Guidance states that a U.S. person may solicit information from covered persons and conduct research to make a determination as to the legality of transactions under U.S. sanctions laws. What are examples of research that would be allowable under the Compliance Services Guidance?#498
- What type of research exceeds the scope of the Compliance Services Guidance?#499
- 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
- Are financial institutions permitted to provide banking services, including processing funds transfers, related to activities authorized under the four categories of the general licenses (GLs) outlined in FAQ 1105? What are OFAC's diligence expectations of financial institutions seeking to engage in such activities?#1106
- 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
- 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
Specially Designated Nationals (SDNs) and the SDN List
- What is an SDN?#18
- How do I get a copy of the Specially Designated Nationals (SDN) List?#19
- How often is the Specially Designated Nationals (SDN) List updated?#20
- How do I know what specific changes have been made to OFAC's Specially Designated Nationals (SDN)List?#21
- What do I do if I have a match to the Specially Designated Nationals (SDN) or one of OFAC's other sanctions lists?#23
- What is the difference between the Specially Designated Nationals (SDN) List and the Commerce Department's List of Denied Parties? Why can't they be integrated into one list? What about OFAC's other sanctions lists?#56
- How do I verify if a name was removed from one of OFAC’s sanctions lists? How do I find the date a Specially Designated National (or other sanctions target) was added to, updated, or removed from an OFAC list?#466
- How can I ask OFAC to remove me or my organization from an OFAC sanctions list?#897
- If my delisting petition requesting removal from an OFAC's sanctions list is denied, may I petition for removal again?#1261
Questions on Virtual Currency
- For purposes of OFAC sanctions programs, what do the terms "digital currency," "digital currency wallet," "digital currency address," and "virtual currency" mean?#559
- Are my OFAC compliance obligations the same, regardless of whether a transaction is denominated in digital currency or traditional fiat currency?#560
- How will OFAC use its existing authorities to sanction those who use digital currencies for illicit purposes?#561
- How will OFAC identify digital currency-related information on the SDN List?#562
- What is the structure of a digital currency address on OFAC’s SDN List?#563
- Is it possible to query a digital currency address using OFAC’s Sanctions List Search tool?#594
- How do I block digital currency?#646
- Should an institution tell its customer that it blocked access to their digital currency and, if so, how does the institution explain it to the customer?#647
Belarus Sanctions
- What does Belarus General License 3 (GL 3), “Authorizing Certain Transactions with the State Security Committee of the Republic of Belarus,” authorize?#912
- Does Belarus GL 3 authorize the exportation of hardware or software to the Belarusian KGB, or where the Belarusian KGB is the end user of such hardware and software?#913
- What does Executive Order (E.O.) of August 9, 2021, “Blocking Property of Additional Persons Contributing to the Situation in Belarus,” do?#916
- Are all persons operating in sectors identified in the Executive Order (E.O.) of August 9, 2021, “Blocking Property of Additional Persons Contributing to the Situation in Belarus,” blocked?#917
- What does Belarus General License 4 (GL 4), “Authorizing the Wind Down of Transactions Involving Belaruskali OAO,” authorize?#918
- What does Belarus General License 5 (GL 5), “Authorizing the Wind Down of Transactions Involving Open Joint Stock Company Belarusian Potash Company or Agrorozkvit LLC,” authorize?#939
- 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?#956
Global Magnitsky Sanctions
- What does Global Magnitsky General License 2A authorize?#835
- I am a U.S. person that owns debt or equity, including publicly traded shares, in Pingtan Marine Enterprise, Ltd. (PME), which was designated under Executive Order (E.O.) 13818. What actions am I authorized to take under Global Magnitsky General License 3?#1100
- What activity does Global Magnitsky General License 4 authorize?#1101
- Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions that U.S. persons would be authorized to engage in under Global Magnitsky General Licenses 3 and 4?#1102
- What does Global Magnitsky General License 5 Authorizing Certain Transactions Related to Frigorifico Chajha S.A.E. authorize?#1111
- What if a governing institution in Afghanistan is led by an individual who has been blocked pursuant to the Global Magnitsky Sanctions Regulations?#1145
- On September 12, 2024, OFAC designated Ly Yong Phat (Ly), L.Y.P. Group Co., LTD (L.Y.P. Group), and the following entities owned by L.Y.P. Group under the Global Magnitsky sanctions authority: O-Smach Resort, Garden City Hotel, Koh Kong Resort, and Phnom Penh Hotel. Can I continue to engage in transactions or other dealings with other entities owned by Ly or L.Y.P. Group that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?#1191
Burma Sanctions
- If there is an active and ongoing investigation against an individual or entity for apparent violations of the Burmese Sanctions Regulations (“BSR”), would that investigation cease now that the President has ended economic and financial sanctions on Burma and the prohibitions in the BSR are no longer in effect?#481
- What does Burma General License 4 authorize?#883
- Does the determination of August 23, 2023, made pursuant to Executive Order (E.O.) 14014 with regard to the jet fuel sector of the Burmese economy mean that all persons that operate or have operated in this sector of the Burmese economy are sanctioned by OFAC?#1132
- For the purposes of the determination of August 23, 2023, made pursuant to Executive Order (E.O.) 14014, what is meant by the term “jet fuel sector of the Burmese economy”?#1133
- What does Directive 1 under Executive Order 14014, "Prohibitions Related to Financial Services to or for the Benefit of Myanma Oil and Gas Enterprise" (MOGE Financial Services Directive) prohibit?#1138
- Does the 50 Percent Rule apply to Directive 1 under Executive Order 14014, “Prohibitions Related to Financial Services to or for the Benefit of Myanma Oil and Gas Enterprise” (MOGE Financial Services Directive)?#1139
Counter Terrorism Sanctions
- As a U.S. person, am I prohibited from engaging in transactions involving information or informational materials, including artwork, that are the property or subject to an interest in property of persons designated as Specially Designated Global Terrorists (SDGTs) under or otherwise blocked pursuant to Executive Order 13224, as amended, (E.O. 13224)?#812
- As a member of the art community, what are my compliance obligations with respect to Executive Order 13224, as amended?#813
- I am currently in possession of artwork in which a Specially Designated Global Terrorist (SDGT) has an interest. What should I do?#814
- What does Counterterrorism-related General License 21B (GL 21B) authorize?#1097
- What transactions does Global Terrorism Sanctions Regulations (GTSR) General License (GL) 27 authorize?#1159
- On March 4, 2025, the Department of State (State) designated Ansarallah as a Foreign Terrorist Organization (FTO). What actions did OFAC take related to this announcement?#1219
Somalia Sanctions
- Can I make a private donation to a charity that is delivering humanitarian assistance in Somalia?#129
- Can my organization provide humanitarian assistance in Somalia?#130
- What if, in delivering humanitarian assistance, my organization unintentionally provides food or medicine to members of al-Shabaab?#131
- What if, in delivering humanitarian assistance, my organization unintentionally provides cash to members of al-Shabaab?#132
- I have heard that certain U.S. humanitarian assistance organizations are exempted from the prohibition on making certain cash payments to al-Shabaab. Is that correct?#133
- I have family members or friends in Somalia and would like to send remittances to them. Can I do that without violating OFAC sanctions?#134
Starting an OFAC Compliance Program
- Does OFAC itself require that banks set up a certain type of compliance program?#25
- What do I need to do to comply? Do I have to buy expensive software?#27
- How often do I need to scan my customer database against OFAC's sanctions lists?#28
- How do I setup a compliance program for my bank?#29
- How do I know if my compliance program is adequate?#30
- What are the features and benefits that banks should be looking for when selecting an OFAC compliance software package?#31
Entities Owned by Blocked Persons (50% Rule)
- Does OFAC consider entities over which one or more blocked persons exercise control, but of which they do not own 50 percent or more in the aggregate, to be blocked pursuant to OFAC’s 50 Percent Rule?#398
- Does OFAC aggregate ownership stakes of all blocked persons when determining whether an entity is blocked pursuant to OFAC’s 50 Percent Rule?#399
- As explained in FAQ 398, OFAC’s 50 Percent Rule does not apply if one or more individuals who are blocked persons (blocked individuals) control, but do not own 50 percent or more of, an entity. Can persons engage in negotiations, enter into contracts, or process transactions involving a blocked individual when that blocked individual is acting on behalf of the non-blocked entity that he or she controls (e.g., a blocked individual is an executive of a non-blocked entity and is signing a contract on behalf of the non-blocked entity)?#400
- OFAC’s 50 Percent Rule states that the property and interests in property of entities directly or indirectly owned 50 percent or more in the aggregate by one or more blocked persons are considered blocked. How does OFAC interpret indirect ownership as it relates to certain complex ownership structures?#401
- How does OFAC’s 50 Percent Rule apply to situations in which one or more blocked persons owned 50 percent or more of an entity, but subsequent to their designations one or more blocked persons divest their ownership stakes in the entity in a transaction that occurs entirely outside of U.S. jurisdiction such that the resulting combined ownership of the entity by blocked persons is less than 50 percent? How should a person treat property or interests in property of such an entity (1) in future transactions (post-divestment) and (2) that was properly blocked while the entity was owned 50 percent or more by one or more blocked persons?#402
Filing Reports with OFAC
- If I reject or block a transaction, when do I have to report the action to OFAC? How do I submit the report?#49
- Is there a requirement for annual reporting of blocked property? Is there a required format?#50
- Is the June 21, 2019 amendment to the Office of Foreign Assets Control (OFAC)'s Reporting, Procedures and Penalties Regulations in effect? Am I required to comply with all requirements of the amended regulations?#819
- I am required to submit a rejected transaction report to OFAC, but I do not have all the information that is required to be reported pursuant to 31 CFR § 501.604(b). Am I required to collect such information from my counterparty just to complete my rejected transaction report?#820
- What should I do if I blocked and reported property in error due to mistaken identity or typographical or similar errors?#1196
Weak Aliases
How to Receive Notifications About OFAC Updates
- Does OFAC have an email service that will notify me when there are updates to any of its sanctions lists?#86
- I'm a subscriber to OFAC's e-mail notification services. For some reason I have stopped receiving the broadcast messages when OFAC updates its website. Why is this?#92
- I recently attempted to subscribe to one of OFAC’s e-mail list services and I have not yet received my confirmation e-mail. Why is this?#93
Promoting Accountability for Assad and Regional Stabilization Sanctions (PAARSS)
- How does [Executive Order (E.O.) 14312](https://ofac.treasury.gov/media/934411/download?inline), "Providing for the Revocation of Syria Sanctions," affect OFAC’s Syria Sanctions Program?#1220
- Can U.S. financial institutions establish relationships with Syrian financial institutions, including the Central Bank of Syria?#1221
- Do I need a specific license from OFAC to export or reexport food or medicine to Syria?#1222