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?

OFAC's answer

Yes. The prohibitions and targeting authorities of amended section 11 of [E.O. 14024](https://ofac.treasury.gov/media/57936/download?inline) apply with respect to any currency. For example, an FFI that processes a significant transaction denominated in a non-USD local currency for a person blocked pursuant to E.O. 14024 or an FFI that processes any significant transaction(s) denominated in a non-USD local currency on behalf of a customer that exports critical items to Russia's military-industrial base, risks being sanctioned by OFAC. For further information on sanctions risk for FFIs under section 11 of E.O. 14024, see OFAC’s [Advisory to Foreign Banks on Russia Sanctions Risks](https://ofac.treasury.gov/media/932436/download?inline), [FAQ 1148](https://ofac.treasury.gov/faqs/1148), and [FAQ 1149](https://ofac.treasury.gov/faqs/1149). Updated: June 12, 2024

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• #1148What 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?
• #1149What 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?