OFAC FAQ #454 · Ukraine-/Russia-related Sanctions

Does General License No. 9 authorize U.S. persons to export or reexport services or software with knowledge or reason to know that such services or software are intended for an individual or entity identified on the Sectoral Sanctions Identification List (SSI List)?

OFAC's answer

[General License No. 9](https://ofac.treasury.gov/media/8976/download?inline) authorizes the exportation or reexportation, directly or indirectly, of certain services and software to persons in the Crimea region of Ukraine, including to individuals and entities identified on the [SSI List](https://ofac.treasury.gov/consolidated-sanctions-list/sectoral-sanctions-identifications-ssi-list) or who are otherwise subject to directives under [Executive Order 13662](https://ofac.treasury.gov/media/5961/download?inline). However, General License No. 9 does not authorize the exportation or reexportation, directly or indirectly, of services or software with knowledge or reason to know that such services or software are intended for any person whose property and interests in property are blocked. Accordingly, U.S. persons engaging in transactions pursuant to General License No. 9 should conduct due diligence to ensure that such transactions do not involve individuals or entities identified on [OFAC’s List of Specially Designated Nationals and Blocked Person](https://ofac.treasury.gov/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists)s or whose property and interests in property are otherwise blocked.

Related programs

ukraine_russia

Read this FAQ on the OFAC site ↗