Will foreign persons be subject to sanctions under the Section 5 of the Ukraine Freedom Support Act (UFSA) or Section 10 of the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act (SSIDES), as amended, respectively, by Sections 226 or Section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) for engaging in activities with GAZ Group or any entity in which GAZ Group 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), [574](https://ofac.treasury.gov/faqs/574), and [579](https://ofac.treasury.gov/faqs/579), 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 a U.S. person would not require a specific license from OFAC to participate in such a transaction. Therefore, activity authorized by General License (GL) 15L, and occurring within the time period authorized by GL 15L, would not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES, as amended by section 228 of CAATSA, or section 5 of UFSA, as amended by section 226 of CAATSA. Date Updated: April 25, 2022

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?
• #579Will 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?