Will foreign persons be subject to sanctions under CAATSA for engaging in activity with RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest?
OFAC's answer
As described in FAQs [542](https://ofac.treasury.gov/faqs/542), [545](https://ofac.treasury.gov/faqs/545), and [574](https://ofac.treasury.gov/faqs/574), a transaction will not be considered “significant” for the purposes of a sanctions determination under section 10 of [SSIDES](https://ofac.treasury.gov/media/5806/download?inline), as amended by section 228 of [CAATSA](https://ofac.treasury.gov/media/5696/download?inline), and section 5 of [UFSA](https://ofac.treasury.gov/media/5811/download?inline), as amended by section 226 of CAATSA, if U.S. persons would not require specific licenses from OFAC to participate in such a transaction. Therefore, activity authorized by General License 14, and occurring within the time period authorized by [General License 14](https://ofac.treasury.gov/media/8876/download?inline), would not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES, as amended by CAATSA, or section 5 of UFSA, as amended by CAATSA.
Related programs
Related FAQs
- #542How does OFAC interpret the following terms as used in section 5 of the Ukraine Freedom Support Act (UFSA), as amended by section 226 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), now incorporated into § 589.209 of the Ukraine-/Russia-Related Sanctions Regulations (URSR): “significant transaction,” “significant financial transaction,” and “facilitated?”
- #545What do the following key terms in section 10 of the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES), as amended by section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), mean: “foreign person,” “knowingly,” “materially violate,” “facilitates . . . for or on behalf of,” “significant transaction,” and “deceptive or structured transaction”?
- #574Will foreign persons be subject to sanctions for doing business with the individuals or entities designated under E.O. 13661 or E.O. 13662, or blocked pursuant to OFAC’s 50 percent rule on April 6, 2018 as a result of such a designation?