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?
OFAC's answer
GLs [6D](https://ofac.treasury.gov/media/932921/download?inline), [7A](https://ofac.treasury.gov/media/922841/download?inline), or [115D](https://ofac.treasury.gov/media/935701/download?inline), or [132](https://ofac.treasury.gov/media/934776/download?inline) do not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of entities subject to the prohibitions of Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” ([Russia-related CAPTA Directive](https://ofac.treasury.gov/media/918471/download?inline)). Consequently, in order for a U.S. financial institution to engage in transactions authorized under these GLs (e.g., a funds transfer related to energy), all such funds transfers must be processed indirectly through a non-sanctioned, non-U.S. financial institution. Examples of authorized and prohibited funds transfers under GLs 6D, 7A, 115D, and 132 include: Payment from third-country originator Authorized payment from third-country originator to beneficiary with an account at a sanctioned institution: Prohibited payment from third-country originator to beneficiary with an account at a sanctioned institution: Payment from U.S. originator Authorized payment from U.S. originator to beneficiary with an account at a sanctioned institution: Prohibited payment from U.S. originator to beneficiary with an account at a sanctioned institution: In each of the above examples, the underlying funds transfer must be authorized under the applicable GL. Updated: June 11, 2026