In those sanctions programs with blocking authorities, OFAC's regulations block all "property" or "interests in property" in which a blocked person has an interest. The term "property" is very broadly defined, including present, future, or contingent interests. (For more information, see FAQ 9.)

For example, if a bank receives payment instructions from a customer to send a wire transfer to a blocked person, the bank should block the funds and report to OFAC through the OFAC Reporting System (ORS) within 10 business days from the date that property becomes blocked by the bank. For additional details on reporting, and to register for access to the ORS, please see the OFAC Reporting System page on OFAC's website.

However, if a customer simply asks a question such as, "Can I send money to Cuba?" then the bank can answer the customer's question or direct the customer to contact the OFAC Compliance Hotline for guidance.

The same logic applies to situations involving prohibited transactions that do not involve any blockable interest that must be rejected under OFAC sanctions regulations. If a bank receives instructions to send funds to a non-blocked person in Iran, then the bank must reject the transfer and file a reject report through ORS, pursuant to 31 CFR § 501.604. If a customer merely asks whether they can send funds to Iran and the bank explains that activity is prohibited, there is nothing to reject. In that situation, the bank does not need to file a report of a rejected transaction.

Date Updated: October 26, 2026

Yes. U.S. persons holding blocked property as of June 30 of the current year must submit an Annual Report of Blocked Property to OFAC no later than September 30 of the same year. Filers are required to use the Annual Report of Blocked Property spreadsheet form (TD F 90-22.50) and submit completed forms through the OFAC Reporting System (ORS). To access the required form or for additional guidance on filing annual reports of blocked property, please see the OFAC Reporting System page on OFAC's website.

Date Updated: October 26, 2026

Reports on blocked property and rejected transactions must be submitted to OFAC through the OFAC Reporting System (ORS) within 10 business days of the date of the action. These reports must include copies of relevant documents that support the information provided in the reports. Examples of supporting documentation include payment or transfer instructions, checks, letters of credit, bills of lading, invoices, or any other pertinent documentation. For more information on requirements for reports on blocked property and rejected transactions, see 31 CFR §§ 501.603 and 501.604, respectively. For additional details on reporting, and to register for access to the ORS, please see the OFAC Reporting System page on OFAC's website.

Holders of blocked property are also required to submit to OFAC annual reports on blocked property. (For more information on Annual Reports of Blocked Property, see FAQ 50.)

Date Updated: October 26, 2026

Generally, U.S. persons should neither open an account for a blocked person nor permit transactions with blocked persons.

U.S. persons, including foreign branches of U.S. financial institutions and others subject to U.S. jurisdiction, are generally prohibited from opening an account for any individual or entity named on OFAC's Specially Designated Nationals and Blocked Persons List (SDN List) or for any individual or entity that is otherwise blocked (such as a blocked government entity or an entity blocked pursuant to OFAC’s "50 Percent Rule"). For more information, see the Basic Information on OFAC and Sanctions FAQ topic page on OFAC's website.

If a U.S. person gains control or possession of any property in which a blocked individual or entity has an interest, however, then the U.S. person is required to block that property and report it to OFAC. (For more information, see FAQ 49.) This means, for example, that if a bank receives an application to open an account—and an initial deposit—from an individual or entity on the SDN List, the bank is obligated to decline to open the account and block the initial deposit.

This blocking requirement also applies to other transactions involving any blocked person. This can be likened to a bouncing ball—once the ball starts moving, it must be stopped if it comes into your possession. If, for example, a customer asks whether they can send money from their U.S. bank to a relative's account with a bank listed on the SDN List, the U.S. bank can say "No. That would be illegal." If, on the other hand, the U.S. bank receives instructions from its customer to debit his or her account and transfer the funds to the blocked bank, the U.S. bank must act on the instructions by blocking the funds that contain a future interest of the blocked bank.

Before taking action, it is important to verify that the individual or entity attempting to open the account or involved in the customer's transaction is the same as the person listed on OFAC's SDN List or that the person is otherwise subject to blocking. There may be instances of "false positives," where the individual's or entity's name is similar to a sanctioned person's name, but the rest of the information provided by the applicant or customer does not match the descriptor information on the SDN List. An institution may need to conduct further due diligence, such as requesting additional identifying information from the individual or entity, to determine whether the match is a "false positive." See FAQ 5 for more information on assessing potential matches to OFAC's sanctions lists.

Date Updated: October 26, 2026

An organization may notify its customer that it has blocked property in accordance with OFAC's regulations and may identify the sanctions program or regulations under which the organization blocked the property. (For more information on OFAC sanctions programs, visit the Sanctions Programs and Country Information page on OFAC's website.) In certain instances, OFAC may issue a blocking order or directive that requires the recipient to promptly disclose such order or directive to affected persons with whom the recipient maintains direct commercial relationships.

The customer may apply to OFAC for a license to unblock and release the funds. For guidance on how to request and apply for a specific license, please see 31 CFR § 501.801 and the OFAC Specific Licenses and Interpretive Guidance page on OFAC's website. (For a list of program tags specific to sanctions programs, which are used when applying for licenses, see the Program Tag Definitions for OFAC Sanctions Lists page on OFAC's website.)

Date Updated: October 26, 2026

In the case of certain sanctions programs, a transaction may be prohibited for U.S. persons, but there may be no blockable interest (i.e., no interest of a Specially Designated National (SDN), blocked government, or other blocked person) in the transaction. In this situation, the transaction should be rejected and returned to the originator. Rejected transactions must not be processed forward to the beneficiary.

The following examples may help illustrate which transactions should be blocked and which should be rejected under certain OFAC sanctions programs. For information on specific prohibitions, authorizations, or exemptions under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC's website.

• A U.S. bank is reviewing a commercial payment destined for the account of XYZ Import-Export Co. at the Bank of XYZ in Iran. The Bank of XYZ is an Iranian financial institution and wholly-owned by the Government of Iran; accordingly, Bank of XYZ is blocked pursuant to 31 CFR § 560.211 (Iranian Transactions and Sanctions Regulations (ITSR)). The U.S. bank must block the payment.
• A U.S. bank is reviewing a commercial payment destined for the account of ABC Import-Export Co. in Tehran, Iran, at a non-blocked bank in a third country. In this example, ABC Import-Export in Tehran is not a blocked person, so there is no blockable interest in this payment. Processing the payment, however, would mean facilitating trade with Iran, exporting a service to Iran, and engaging in a trade-related transaction with Iran. These activities are prohibited pursuant to 31 CFR §§ 560.204, 560.206, and 560.208 of the ITSR, so the U.S. bank must reject the payment.
• A U.S. bank is reviewing a wire transfer destined for an individual in the Crimea region of Ukraine. The individual is not a blocked person, and there is no other blockable interest in this payment. Processing the payment, however, would mean exporting a service to the Crimea region of Ukraine, which is prohibited pursuant to 31 CFR § 589.207 (Ukraine-/Russia-Related Sanctions Regulations (URSR)); therefore, the U.S. bank must reject the payment.

Blocked and rejected transactions must be reported to OFAC through the OFAC Reporting System (ORS) within 10 business days, pursuant to 31 CFR §§ 501.603 and 501.604. To register for access or to log in to ORS, please see the OFAC Reporting System page on OFAC's website.

Date Updated: October 26, 2026

No. Each OFAC sanctions program is based on different underlying authorities and foreign policy and national security goals, so the prohibitions imposed vary between programs. Most programs block the property and interests in property of specific individuals and entities. Certain programs do not require blocking of any property; instead, they generally prohibit U.S. persons from engaging in certain trade or financial transactions and other dealings with specified persons or jurisdictions.

When a particular sanctions program prohibits transactions but does not impose blocking requirements, an institution may be required to reject, rather than block, the prohibited transactions. As with blocked transactions, rejected transactions must also be reported to OFAC through the OFAC Reporting System (ORS), within 10 business days, pursuant to 31 CFR § 501.604. To register for access or to log in to ORS, please see the OFAC Reporting System page on OFAC's website.

For more information on rejecting transactions, see FAQ 36. For information on specific prohibitions, authorizations, or exemptions under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC's website.

Date Updated: October 26, 2026

Generally, yes. Most OFAC regulations contain licenses allowing a U.S. financial institution to debit blocked accounts for normal service charges, which are described within the relevant OFAC implementing regulations for each sanctions programs. The service charges must be normal, for example, in accordance with a published rate schedule for the type of account in which the funds are maintained.

Date Updated: October 26, 2026

OFAC regulations require that blocked funds earn interest at a commercially reasonable rate, i.e., at a rate currently offered to other depositors on deposits or instruments of comparable size and maturity.

Date Updated: October 26, 2026

Once it is determined that funds need to be blocked, the funds must be placed into a segregated, interest-bearing account on a U.S. financial institution's books, from which only OFAC-authorized debits may be made. The holder of the blocked funds must then report the funds as blocked property to OFAC through the OFAC Reporting System (ORS) within 10 business days, pursuant to 31 CFR § 501.603. To register for access, or to log in to ORS, please see the OFAC Reporting System page on OFAC's website.

When blocking funds, some institutions open separate accounts for each blocked transaction, while others opt for blocked omnibus accounts. Either method is consistent with regulatory requirements, provided there is a clear audit trail, including so the institution can later unblock specific funds with the appropriate interest, if authorized to do so. Please note, pursuant to 31 CFR § 501.603(d)(1), institutions maintaining blocked funds in omnibus accounts must include in their Annual Report of Blocked Property a disaggregated list showing each blocked asset contained within the omnibus account. For more information on annual reporting of blocked property, see FAQ 50.

Please see OFAC's answers to FAQs on Filing Reports with OFAC for more information. For information on blocking digital currency, see FAQ 646. For information on blocking within the insurance industry, see FAQ 62. If, after reviewing this guidance, you have questions about blocking funds in other contexts, please contact the OFAC Compliance Hotline.

Date Updated: October 26, 2026

While OFAC does not maintain a specific list of countries with which U.S. persons may not do business, the Sanctions Programs and Country Information page on OFAC's website provides a list of sanctions programs administered by OFAC. OFAC implements, administers, and enforces U.S. economic sanctions that target either a particular jurisdiction (i.e., a country or geographic region) or specified activities (e.g., terrorism or narcotics trafficking) anywhere in the world. Within each sanctions program, OFAC may implement various types of sanctions based on different foreign policy and national security goals. Most programs include sanctions blocking the property of specific individuals or entities, while some of the most comprehensive programs broadly prohibit transactions or dealings involving an entire jurisdiction. Each sanctions program is unique, and sanctions programs may change frequently. For up-to-date information on an OFAC sanctions program, including applicable exemptions and authorizations, you always should carefully review the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC's website.

Broad jurisdiction-based sanctions: Several OFAC sanctions programs apply broad jurisdiction-based sanctions that generally prohibit U.S. persons from engaging in most transactions or dealings involving that particular jurisdiction, such as exporting or importing goods, services, or technology to or from that jurisdiction. As of this FAQ's publication (please see "date updated" at the bottom of this text), jurisdictions subject to such broad sanctions (at times referred to as comprehensive sanctions) include:

• Cuba;
• Iran;
• North Korea;
• The Crimea region of Ukraine; and
• The so-called Donetsk People's Republic and Luhansk People's Republic regions of Ukraine.

Additionally, although the Russian Federation is not subject to the same degree of jurisdiction-based prohibitions, OFAC sanctions prohibit certain categories of transactions with Russia, including the export and import of certain goods and services to or from Russia. (See OFAC's Russia-related sanctions programs for more detail.)

Government blocking sanctions: Some OFAC sanctions programs apply government blocking sanctions, which require the blocking of all property and interests in property of a particular foreign government or regime that are or come within U.S. jurisdiction. Each government subject to these sanctions is defined within the relevant authorities, but generally, the definition of the blocked government includes any political subdivision, agency, or instrumentality (including any entity owned or controlled directly or indirectly by any of the foregoing). As of this FAQ's publication (please see "date updated" at the bottom of this text), foreign governments subject to such government blocking sanctions include:

• Government of Cuba;
• Government of Iran;
• Government of North Korea; and
• Government of Venezuela.

Aside from programs that employ these broad sanctions, many OFAC sanctions programs that relate to a particular jurisdiction employ more limited sanctions prohibitions and do not generally prohibit activity with the jurisdiction nor block the jurisdiction's government (e.g., OFAC's Nicaragua-related Sanctions program does not generally prohibit transactions involving Nicaragua, and similarly, OFAC's Democratic Republic of the Congo (DRC)-Related Sanctions program targets, in part, persons threatening the peace, security, or stability of the DRC and the surrounding region). Note that programs such as these may include sanctions against certain government officials or entities without blocking the entire government of the subject jurisdiction. Most OFAC sanctions programs impose sanctions, such as blocking sanctions, on targeted persons (i.e., individuals and entities). For example, persons appearing on OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List) are blocked pursuant to OFAC regulations and other authorities. When such list-based blocking sanctions apply, generally U.S. persons are prohibited from engaging in transactions involving blocked persons wherever such blocked persons are located, and all property of blocked persons within U.S. jurisdiction (including within the possession or control of U.S. persons, wherever located) must also be blocked. Aside from blocking sanctions, OFAC may impose non-blocking prohibitions on targeted persons, which may appear on other sanctions lists maintained by OFAC (referred to as Non-SDN Lists). Note that not all sanctioned persons are located in sanctioned jurisdictions; sanctioned persons can be located anywhere in the world.

For more information on OFAC's sanctions lists, see OFAC's Sanctions List Service tool, the OFAC Basics video series, and Frequently Asked Questions (FAQs) on Basic Information on OFAC and Sanctions, Specially Designated Nationals (SDNs) and the SDN List, and How to Search OFAC's Sanctions Lists.

Date Updated: October 26, 2026

OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries ("LIG Entities"): GL 128D and GL 131K. The GLs are similar but have different expiration dates and terms as each serves a different purpose.

• To mitigate the effects of Lukoil's OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. OFAC subsequently issued GL 128C and GL 128D to extend the existing authorization until April 24, 2027.
• To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. OFAC subsequently issued GLs 131B, 131C, 131D, GL 131E, GL 131F, GL 131G, GL 131H, GL 131I, GL 131J, and GL 131K to extend the existing authorization until November 21, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

GL 128D and GL 131K expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128D and GL 131K. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128D and GL 131K authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.

Both GL 128D and GL 131K also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.

Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128D and GL 131K. Similarly, non-U.S. persons may rely upon GL 128D and GL 131K regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person's activities are consistent with the terms of GL 128D and GL 131K, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

Date Updated: October 21, 2026

On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia's energy sector and degrade Russia's ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131K, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG's majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131K expires on November 21, 2026.

GL 131K does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131K must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC's Russia sanctions is to place pressure on Moscow to end its war.

As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives. OFAC expects that, at a minimum, the proposed transaction must: completely sever LIG's ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps. Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG's assets to seek OFAC review before further divestment of material LIG assets.

OFAC may revoke GL 131K at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.

Date Updated: October 21, 2026

No. GL 60A authorizes all transactions related to earthquake relief efforts in Venezuela under the Venezuela Sanctions Regulations, which includes payment of taxes, tolls, and fees to the Government of Venezuela connected with such relief efforts. Payments related to earthquake relief that are authorized by GL 60A do not need to be paid into the FGDF.

However, the requirements under other Venezuela-related GLs, such as GLs 46E, 48C, 49B, 50C, 51D, 52C, and 54C, remain in place. Payments for activities outside of the scope of GL 60A but authorized under other Venezuela-related GLs that contain the FGDF payment requirement must continue to be paid into the FGDF and may not be recharacterized as earthquake relief or otherwise modified for the purpose of avoiding payment into the FGDF.

Date Updated: October 16, 2026

The U.S. government does not intend to target foreign persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the divestment from or the wind down of transactions involving BICSA, or any entity in which BICSA owns, directly or indirectly, a 50 percent or greater interest, through November 14, 2026. However, non-U.S. persons, including FFIs, should proceed with caution in any dealings with a party sanctioned under this authority. Actions to return assets to a sanctioned party or transfer them to another jurisdiction for potential use by the target could expose non-U.S. persons to significant sanctions risk.

Foreign persons unable to divest from or wind down transactions involving BICSA, or any entity in which BICSA owns, directly or indirectly, a 50 percent or greater interest, before November 14, 2026, are encouraged to contact the OFAC Compliance Hotline.

Persons subject to U.S. jurisdiction, including U.S. persons and entities owned or controlled by U.S. persons, should additionally note that this limited non-targeting posture does not authorize any transaction prohibited by the Cuban Assets Control Regulations (CACR), 31 CFR part 515, or any other OFAC sanctions authority. Persons subject to U.S. jurisdiction have long been prohibited from transacting with BICSA, a Cuban State-Owned entity, absent OFAC authorization. Accordingly, persons subject to U.S. jurisdiction continue to be prohibited from engaging in transactions involving BICSA, including in connection with a non-U.S. person's wind down of activities with BICSA, unless separately authorized by OFAC. Relevant authorizations may include humanitarian and diplomatic-related transactions authorized under the CACR in subpart E of part 515 and under E.O. 14404 via General License (GL) 1 and GL 4A. For additional information on GL 1, see FAQ 1253.

On October 5, 2026, OFAC issued a notice alerting foreign financial institutions that continue to do business with Iran or its financial sector to the risk of sanctions under “Operation Economic Outcast.” If the Treasury Department makes a finding that a foreign financial institution knowingly engages in one or more sanctioned activities, as described in FAQ 155, and decides to impose strict condition(s), the Treasury Department will issue an order or a regulation that sets out the strict condition(s) to be imposed on the U.S. correspondent accounts or U.S. payable-through accounts of the relevant foreign financial institution, and will publish the order or regulation in the Federal Register. The Federal Register is available at www.govinfo.gov. If the Treasury Department decides to prohibit the opening or maintaining of U.S. correspondent accounts or U.S. payable-through accounts for a foreign financial institution, the Treasury Department will add the name of the foreign financial institution and publish it to the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List).

Date Updated: October 5, 2026

E.O. 13902 imposes sanctions with respect to any person determined by the Secretary of the Treasury to operate in the construction, mining, manufacturing, and textiles sectors of the Iranian economy, and any additional sectors of the Iranian economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State. On October 8, 2020, the Secretary of the Treasury identified the financial sector of the Iranian economy for additional sanctions under E.O. 13902. Iranian and non-Iranian persons operating in these sectors of the Iranian economy or sectors of the Iranian economy identified in the future could be subject to sanctions.

OFAC expects to promulgate regulations that define the terms construction sector of the Iranian economy, mining sector of the Iranian economy, manufacturing sector of the Iranian economy, textiles sector of the Iranian economy, and financial sector of the Iranian economy consistent with the following:

Construction sector of the Iranian economy: The term construction sector of the Iranian economy means the production, procurement, devising, framing, or arranging in Iran of parts or materials to fabricate, shape, or form buildings or structures, including the on-site development, assembly, or construction of residential, commercial, or institutional buildings in Iran. The term applies to engaging in new work, additions, alterations, maintenance, and repairs of residential, commercial, or institutional buildings. Persons such as for-sale builders, design-build firms, and project construction management firms in Iran may be considered as operating in this sector.

Mining sector of the Iranian economy: The term mining sector of the Iranian economy means any act, process, or industry of extracting, at the surface or underground, ores, coal, precious stones, or any other minerals or geological materials from the Earth in Iran.

Manufacturing sector of the Iranian economy: The term manufacturing sector of the Iranian economy means the creation in Iran of goods by manual labor or machinery that are for export from Iran or for sale within Iran. For the purposes of evaluating sanctions pursuant to E.O. 13902, persons in Iran manufacturing medicines, medical devices, or products used for sanitation, hygiene, medical care, medical safety, and manufacturing safety, including soap, hand sanitizer, ventilators, respirators, personal hygiene products, diapers, infant and childcare items, personal protective equipment, and manufacturing safety systems, solely for use in Iran and not for export from Iran, will not be considered to be operating in the manufacturing sector of the Iranian economy. Note that persons conducting or facilitating transactions for the provision, including any sale, of agricultural commodities, food, medicine, or medical devices to Iran will not be subject to sanctions under E.O. 13902.

Textiles sector of the Iranian economy: The term textiles sector of the Iranian economy means the fiber synthesis, dyeing, weaving, knitting, or felting in Iran of textiles, including apparel, carpets, cloths, fabric, or related goods, that are for export from Iran.

Financial sector of the Iranian economy: The term financial sector of the Iranian economy includes (1) all Iranian financial institutions as defined in Section 561.320 of the Iranian Financial Sanctions Regulations and (2) providers of economic or financial services in or involving Iran, including government-operated and private banks and financial institutions, savings banks, trust companies, credit card companies, investment banking services, foreign exchange services, money services businesses, payday lenders, mortgage companies, securities and commodities exchanges, securities brokers and dealers, commodity futures and options brokers and dealers, clearing corporations, asset managers, employee benefit plans, dealers in precious metals, stones, or jewels, and insurance companies, or any persons that are engaged in the business of accepting deposits, transferring funds, facilitating investment, making, granting, transferring, holding, or brokering loans or credits, or purchasing or selling foreign exchange, securities, commodity futures or options, or procuring purchasers and sellers thereof, as principal or agent, and any related activities, including the provision or receipt of goods, services, or technology to or involving the financial sector of the Iranian economy, as well as holding companies, affiliates, or subsidiaries of the foregoing, and other persons that, directly or indirectly, own or control providers of such services.

Persons who knowingly engage in a significant transaction for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with the above-named sectors of the Iranian economy risk exposure to blocking sanctions pursuant to E.O. 13902. In addition, persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, persons designated pursuant to E.O. 13902 could themselves be designated. Furthermore, foreign financial institutions that have knowingly conducted or facilitated any significant financial transaction for such designated persons risk exposure to U.S. correspondent account or payable-through account sanctions.

Date Updated: October 1, 2026

Simultaneous Publish Test

Effective September 30, 2026, OFAC amended § 515.564 to eliminate the authorization related to the attendance at, or organization of, professional meetings or conferences in Cuba. Persons subject to U.S. jurisdiction are no longer authorized to attend or organize professional meetings or conferences in Cuba. OFAC is replacing that authorization with a limited wind down authorization for persons subject to U.S. jurisdiction who were in Cuba on September 30, 2026 pursuant to the former professional meetings authorization to engage in travel-related and other previously authorized transactions through October 30, 2026, provided they depart Cuba by October 30, 2026. In addition, OFAC is also authorizing persons to terminate and obtain refunds for travel and related transactions for trips consistent with the former professional meetings authorization until October 30, 2026.

Section 515.590 of the CACR authorizes the provision of certain grants, scholarships, or awards to Cuban nationals or in which Cuba or a Cuban national has an interest. Such grants, scholarships, or awards must relate to educational activities, certain humanitarian projects (as set forth in § 515.575 (b)), scientific research, or religious activities. This general license excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.590. 

Date Updated: September 29, 2026

Yes, provided that the insurance policy is a global policy, and not specific to the third-country national’s travel to or within Cuba. Section 515.580 of the CACR authorizes persons subject to U.S. jurisdiction to issue or provide global health, life, or travel insurance policies for individuals ordinarily resident in a country outside of Cuba who travel to or within Cuba, regardless of whether the insurance policy is issued only to that individual or to a group, such as to all employees of a particular company. For instance, a U.S. insurer may pay medical claims pursuant to a group health insurance policy to or on behalf of a covered third-country national injured while traveling in Cuba. However, this provision does not authorize a person subject to U.S. jurisdiction to issue an insurance policy that is specific to travel to Cuba. A separate provision of the CACR, § 515.560, authorizes the provision of health, life, and travel insurance-related services that are specific to Cuba for authorized U.S. travelers. However, please note that § 515.560 excludes from the authorization at § 515.560(c)(2) the lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210, as well as any direct or, effective September 30, 2026, indirect financial transactions with any entity or subentity on the State Department's Cuba Restricted List. For a complete description of the scope of this prohibition, see 31 CFR § 515.210.

Date Updated: September 29, 2026

Section 515.533(a) of the CACR does not restrict payment and financing terms for exports of items from the United States or reexports of 100 percent U.S-origin items from a third country, other than agricultural commodities. Examples of permissible payment and financing terms for authorized exports and reexports that are not agricultural commodities include: payment of cash in advance; sales on an open account; and financing by U.S. or third-country financial institutions.

OFAC has issued a general license authorizing banking institutions to provide financing for such authorized exports or reexports of items other than agricultural commodities, including issuing, advising, negotiating, paying, or confirming letters of credit (including letters of credit issued by a financial institution that is a national of Cuba), accepting collateral for issuing or confirming letters of credit, and processing documentary collections. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.584(f). With the exception of transactions related to exports or reexports of medicines or medical supplies, items associated with the provision of telecommunications and internet services for the Cuban people, or items associated with air and sea operations that support permissible travel, cargo, or trade, the general license at § 515.584(f) excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a description of the scope of the prohibition on direct and indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209.

Date Updated: September 29, 2026

Pursuant to 31 CFR § 515.573, persons subject to U.S. jurisdiction may establish and maintain a physical presence, such as an office, warehouse, or retail outlet, in Cuba to engage in transactions authorized by or exempt from the CACR in the following categories: entities engaging in non-commercial activities authorized by section 515.574 (support for the Cuban people); entities engaging in humanitarian projects set forth in section 515.575(b) (humanitarian projects); private foundations or research or educational institutes engaging in transactions authorized by § 515.576; news bureaus; exporters of certain goods authorized for export or reexport pursuant to 31 CFR §§ 515.533 and 515.559; entities providing mail or parcel transmission services; providers of telecommunications or internet-based services; entities organizing or conducting certain educational activities; religious organizations; and providers of carrier and certain travel services. These persons may employ Cuban nationals in Cuba as well as persons subject to U.S. jurisdiction in Cuba (and such persons may maintain a domicile in Cuba). These persons may open and maintain bank accounts to facilitate authorized transactions. 31 CFR § 515.573 excludes from the authorization direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.573. Persons subject to U.S. jurisdiction that do not meet the terms of the general license may apply to OFAC for a specific license. Such applications will be reviewed on a case-by-case basis. Additional authorizations from the Cuban government may also be required.

Date Updated: September 29, 2026

Trade delegations are authorized to travel to Cuba only if each member of the delegation meets the criteria of an applicable general license authorizing travel to Cuba or has obtained a specific license from OFAC. Authorized trade delegations generally fall under one of two general licenses for travel authorization: either (1) 31 CFR § 515.533(c)(1), which authorizes travel-related and other transactions incident to the exportation of certain authorized goods from the U.S. to Cuba, specifically the conduct of "market research, commercial marketing, sales or contract negotiation, accompanied delivery, installation, leasing, servicing, or repair in Cuba of items consistent with the export or reexport licensing policy of the Commerce Department,” or (2) 31 CFR § 515.564(a)(1), which authorizes transactions related to professional research in Cuba. Both general licenses exclude from the authorizations lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210.  For a complete description of the scope of this prohibition, see 31 CFR § 515.210.  In addition, the general license related to professional research in Cuba excludes from its authorization direct or, effective September 30, 2026, indirect financial transactions with entities or subentities identified on the State Department’s Cuba Restricted List.  For a complete description of the scope of this prohibition, see 31 CFR § 515.209.

Date Updated: September 29, 2026

The names of the entities and subentities that the State Department identifies as under the control of, or acting for or on behalf of, or for the benefit of, the Cuban military, intelligence, or security services or personnel and with which direct or indirect financial transactions would disproportionally benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba are published on the Cuba Restricted List (CRL), which is available on the State Department’s website and in the Federal Register (updates to the CRL will also be published in the Federal Register).  Entities or subentities that are owned or controlled by another entity or subentity on the CRL are not treated as restricted unless also specified by name on the CRL.

Date Updated: September 29, 2026

Persons subject to U.S. jurisdiction are prohibited from doing business or investing in Cuba unless authorized by OFAC.  An OFAC general license authorizes, subject to certain conditions and limitations, the exportation from the United States, and the reexportation from third countries, of items to Cuba where the exportation or reexportation is licensed or otherwise authorized by BIS.  See 31 CFR § 515.533(a). BIS currently authorizes certain categories of items to be exported or reexported to Cuba. In addition, OFAC currently generally licenses the establishment of a business presence or physical presence in Cuba for certain types of entities or persons.  See 31 CFR § 515.573. The general licenses for the establishment of a business presence or physical presence in Cuba exclude from the authorizations direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209.

No. Effective September 30, 2026, banking institutions subject to U.S. jurisdiction are prohibited from processing "U-turn" transactions, i.e., funds transfers originating and terminating outside the United States, where neither the originator nor the beneficiary is a person subject to U.S. jurisdiction. However, banking institutions subject to U.S. jurisdiction are authorized pursuant to 31 CFR § 515.584(d) to reject (vice block) such "U-turn" transactions.

Date Updated: September 29, 2026

Yes. Subject to certain exceptions, transactions that are ordinarily incident to an authorized transaction are permitted. See the examples in 31 CFR § 515.421. Such transactions may include use of online payment platforms to facilitate authorized transactions. Authorized transactions ordinarily incident to licensed transactions exclude any direct or, effective September 30, 2026, indirect financial transaction with Cuba Restricted List (CRL) entities, as well as lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210, if the terms of the applicable general or specific license expressly exclude such transactions. See 31 CFR § 515.421(5)-(6). Also, 31 CFR § 515.421 tfurther notes that a transaction relating to the collection, forwarding, or receipt of remittances involving any entity or subentity identified on the CRL is not authorized as an ordinarily incident transaction where the terms of the general or specific license expressly exclude any such transactions. For a complete description of the scope of transactions ordinarily incident to a licensed transaction and the restrictions and exceptions that apply, see 31 CFR § 515.421.

Date Updated: September 29, 2026

No. To the extent the transaction involves an entity or subentity on the Cuba Restricted List, a financial institution can rely on the statements of its customer or information available to them in the ordinary course of business that the transaction is authorized unless it knows or has reason to know the transaction is not authorized. A banking institution is expected to conduct a level of due diligence commensurate with its overall risk profile and internal compliance policies and procedures with respect a transaction involving Cuba or a Cuban national and which may be authorized pursuant to the Cuban Assets Control Regulations.

Date Updated: September 29, 2026

Yes. Section 515.584(h) of the CACR contains a general license that allows banking institutions to open and maintain bank accounts in the United States solely in the name of a Cuban national located in Cuba, to receive payments in the United States for transactions authorized pursuant to, or exempt from the prohibitions of, the CACR and to remit such payments back to Cuba, including through an online payment platform. For example, an author who is a Cuban national located in Cuba may open an account with a bank in the United States to receive payments for sales of their book.

On September 30, 2026, OFAC amended § 515.584 to remove the authorization for U.S. banking institutions to open and maintain an account solely in the name of a Cuban national who is an independent private sector entrepreneur (as defined in 31 CFR § 515.340) for the purpose of conducting authorized or exempt transactions. Unless separately authorized, banking institutions subject to U.S. jurisdiction are required to immediately block these funds and accounts, and will require a specific license from OFAC to unblock any such accounts or funds.

Date Updated: September 29, 2026

Yes. Pursuant to section 515.571(a)(5) of the CACR, banking institutions are permitted to maintain accounts for certain Cuban nationals present in the United States in a non-immigrant status or pursuant to other non-immigrant travel authorization. Although the account may remain open while the Cuban national is not in the United States, access to such accounts must be limited to periods during which the Cuban national is lawfully present in the United States. For a complete description of what the OFAC general license authorizes and the restrictions that apply, see 31 CFR § 515.571(a)(5).

Date Updated: September 29, 2026

Yes.  Persons subject to U.S. jurisdiction who are traveling to Cuba pursuant to one of the 12 authorized categories of travel may open and maintain bank accounts in order to access funds while located in Cuba for authorized transactions, and are authorized to close such accounts.  For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR §  515.560(c)(6). This general license excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209.

Yes, under certain circumstances. Persons subject to U.S. jurisdiction may engage in transactions in U.S. dollars in Cuba or with Cuban nationals with respect to activity that is authorized pursuant to the Cuban Assets Control Regulations (CACR). For example, payments for telecommunications services in Cuba provided pursuant to 31 CFR § 515.542 may be provided in U.S. dollars. Further, the use of U.S. dollars for transactions that are exempt from the prohibitions of, or authorized by, the CACR is also allowed. For example, payments related to the importation or exportation of informational materials as defined in 31 CFR § 515.332, such as books or musical recordings, may be made in U.S. dollars.

Please note that, effective September 30, 2026, banking institutions subject to U.S. jurisdiction are no longer authorized to process transactions in which Cuba or a Cuban national has an interest that originate and terminate outside the United States, even where neither the originator nor the beneficiary is a person subject to U.S. jurisdiction (i.e., "U-turn" transactions). Such banking institutions are now only authorized to reject (vice block) these transactions.

Date Updated: September 29, 2026

Section 515.209 prohibits persons subject to U.S. jurisdiction from engaging in a direct or, effective September 30, 2026, an indirect financial transaction with entities and subentities on the CRL. A person engages in a direct financial transaction by either acting as the originator on a transfer of funds whose ultimate beneficiary is on the CRL or as the ultimate beneficiary on a transfer of funds whose originator is an entity or subentity on the CRL, including a transaction by wire transfer, credit card, check, or payment of cash. A person engages in an indirect financial transaction by participating in a transfer of funds despite not acting as an originator or ultimate beneficiary of that funds transfer, where either the originator or the ultimate beneficiary is an entity or subentity on the CRL, including a transaction by wire transfer, credit card, check, or payment of cash. This definition of "indirect financial transaction" is unique to the Cuban Assets Control Regulations and should not be interpreted to apply to other OFAC programs.
Below are some examples of direct and indirect financial transactions that 31 CFR § 515.209 would prohibit.

Direct Financial Transactions

1. A person subject to U.S. jurisdiction is traveling to Cuba to engage in an authorized family visit pursuant to 31 CFR § 515.561. The traveler books and pays for a hotel room directly with a hotel included on the CRL. This is a prohibited direct financial transaction because the traveler is a person subject to U.S. jurisdiction who would be the originator of a transfer of funds (i.e., payment for the room) whose ultimate beneficiary would be a hotel that is on the CRL.
2. An individual working for a church subject to U.S. jurisdiction is interested in establishing a physical presence in Cuba pursuant to 31 CFR § 515.573(d)(3). The individual signs a new contract directly with a real estate company on the CRL to rent a location for the church’s physical presence, and the church begins making rent payments shortly thereafter. This is a prohibited direct financial transaction because the church is a person subject to U.S. jurisdiction who would be originating a transfer of funds (i.e., rent payments) whose ultimate beneficiary would be an entity on the CRL.
3. A person subject to U.S. jurisdiction is traveling to Cuba to engage in professional research pursuant to 31 CFR § 515.564(a). The traveler books a stay a hotel that is on the CRL through a travel agency that is not subject to U.S. jurisdiction. The traveler pays for the trip, including for the room at the hotel, through the travel agency so that the traveler pays the travel agency, which in turn pays the Cuban entities, including the hotel. This is a prohibited direct financial transaction because the traveler is a person subject to U.S. jurisdiction who would be originating a transfer of funds (i.e., payment for the room) whose ultimate beneficiary would be an entity on the CRL.

Indirect Financial Transactions

1. A Cuban beverage manufacturer on the CRL seeks to pay for goods provided by a fruit supply company that is not subject to U.S. jurisdiction. The payment is routed to the fruit supply company’s bank via a U.S. correspondent bank. This is a prohibited indirect financial transaction because the U.S. bank is acting as an intermediary in a transfer of funds that originates from an entity on the CRL.
2. A U.S. banking institution processes a payment from a non-U.S. person tourist for goods at a Cuban store on the CRL. This is a prohibited indirect financial transaction because the U.S. banking institution is acting as an intermediary in a transfer of funds where the ultimate beneficiary is an entity on the CRL.
3. A U.S. banking institution processes a payment from a non-U.S. person tourist to a Cuban hotel on the CRL. This is a prohibited indirect financial transaction because the U.S. banking institution is acting as an intermediary in a transfer of funds where the ultimate beneficiary is an entity on the CRL.

Please note that § 515.201(c) also prohibits any transaction for the purpose or which has the effect of evading or avoiding § 515.209’s prohibition on engaging in a direct or indirect financial transaction with entities or subentities on the CRL.

Date Updated: September 29, 2026

The State Department publishes a list of entities and subentities that the Secretary of State has determined are under the control of, or act for, on behalf of, or for the benefit of the Cuban military, intelligence, or security services or personnel, and with which direct or indirect financial transactions would disproportionately benefit the Cuban military, intelligence, or security services or personnel at the expense of the Cuban people or private enterprise in Cuba. This list is called the Cuba Restricted List (CRL), and is available on the State Department's website at https://www.state.gov/division-for-counter-threat-finance-and-sanctions/cuba-restricted-list.

The Cuban Asset Control Regulations (CACR) prohibit any direct or, effective September 30, 2026, indirect financial transaction with entities and subentities on the CRL. For a complete description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209. Please see FAQ 735 for additional information regarding a "direct financial transaction" and "indirect financial transaction." Please see FAQ 1271 for additional information on the effect of OFAC's September 30, 2026 amendment to the CACR on the CRL.

The prohibition on direct or indirect financial transactions with entities and subentities on the CRL applies to the following general licenses: §§ 515.530 (powers of attorney); 515.534 (contingent contracts); 515.545 (information/informational materials); 515.560 (travel-related transactions); 515.561 (family visits); 515.564 (professional research); 515.565 (educational activities); 515.566 (religious activities); 515.567 (public performances); 515.572 (travel services); 515.573 (physical and business presence in Cuba); 515.574 (support for the Cuban people); 515.576 (private foundations or research or educational institutes); 515.577 (publishing); 515.578 (internet-based services); 515.581 (conferences in third countries); 515.584 (certain financial transactions); and 515.590 (certain grants, scholarships, and awards). For a complete description of what each general license authorizes and the restrictions that apply, see the aforementioned general licenses.

The CACR also excludes from the scope of certain remittance-related general licenses any transactions relating to the collection, forwarding, or receipt of remittances involving any entity or subentity identified on the CRL. This restriction is distinct from the prohibition in § 515.209, which, for example, contains certain exceptions for pre-existing commercial engagements with CRL entities or subentities. See Note 2 to § 515.209, reinforcing this distinction. Specifically, OFAC excludes from the scope of certain general licenses any transaction relating to the collection, forwarding, or receipt of remittances involving any entity or subentity on the CRL, regardless of the existence of any pre-existing commercial engagements.

In addition, § 515.421 of the CACR contains an interpretive provision for incidental transactions where OFAC has clarified that authorized transactions ordinarily incident to licensed transactions and necessary to give effect thereto exclude direct and indirect financial transactions with such entities or subentities on the CRL if the terms of the applicable general or specific license expressly exclude such direct or indirect financial transactions. Section 515.421 also clarifies that a transaction relating to the collection, forwarding, or receipt of remittances involving any entity or subentity identified on the CRL is not authorized as an ordinarily incident transaction where the terms of the general or specific license expressly exclude any such transactions. For a complete description of the scope of the interpretive provision and the restrictions and exceptions that apply, see 31 CFR § 515.421.

Finally, effective September 30, 2026, § 515.201(c) prohibits any transaction that has the purpose or effect of evading or avoiding the prohibitions on direct or indirect transactions with entities or subentities on the CRL.

Date Updated: September 29, 2026

No.  A general license authorizes persons subject to U.S. jurisdiction, including travel agents and tour group operators, to provide travel services in connection with authorized travel without the need for specific licenses from OFAC.  For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.572(a)(1). This general license excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. This general license further excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210. For a complete description of the scope of this prohibition, see 31 CFR § 515.210. The provision of services related to travel for tourist activities or other unauthorized travel to Cuba remains prohibited. 

There is no specific dollar limit on authorized expenses; however, the Cuban Assets Control Regulations restrict persons subject to U.S. jurisdiction from engaging in direct or, effective September 30, 2026, indirect financial transactions with entities or subentities identified on the State Department’s Cuba Restricted List, with certain exceptions. See 31 CFR §§ 515.209 and 515.421.  Consistent with these authorizations and restrictions, authorized travelers may engage in transactions ordinarily incident to travel within Cuba, including payment of living expenses and the acquisition in Cuba of goods for personal consumption there. 31 CFR § 515.421 also  excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the State Department’s Cuba Prohibited Accommodations List to the extent prohibited by 31 CFR § 515.210.  For a complete description of the scope of this prohibition, see 31 CFR § 515.210. In addition, travelers are authorized to acquire in Cuba and import as accompanied baggage into the United States merchandise for personal use only; this authorization excludes imports into the United States of Cuban-origin alcohol or tobacco products.  OFAC considers “personal use” of an imported item to include giving the item to another individual as a personal gift, but not the transfer of the item to another person for payment or other consideration. Value imports remain subject to the normal limits on duty and tax exemptions for merchandise imported as accompanied baggage and for personal use. 

The general license at 31 CFR § 515.545(b)(1) authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to the exportation, importation, or transmission of information or informational materials. This general license excludes from its authorization direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department's Cuba Restricted List. This general license also excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210. For a complete description of the scope of this prohibition, see 31 CFR § 515.210. The traveler's schedule of activities must not include free time or recreation in excess of that consistent with a full- time schedule in Cuba. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.545(b)(1).

The general license at 31 CFR §515.545(b)(2) authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to professional media or artistic productions of information or informational materials for exportation, importation, or transmission, including the filming or production of media programs (such as movies and television programs), the recording of music, and the creation of artworks in Cuba, provided that the traveler is regularly employed in or has demonstrated professional experience in a field relevant to such professional media or artistic productions. This general license excludes from the authorization direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department's Cuba Restricted List. This general license also excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210. For a complete description of the scope of this prohibition, see 31 CFR § 515.210. The traveler's schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.545(b)(2). The definition of "information and informational materials" may be found at 31 CFR § 515.332.

Date Updated: September 29, 2026

Section 515.576 of the CACR contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to activities by private foundations or research or educational institutes with an established interest in international relations to collect information related to Cuba for noncommercial purposes, among other things. This general license excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department's Cuba Restricted List. This general license also excludes lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210. For a complete description of the scope of this prohibition, see 31 CFR § 515.210. The traveler's schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule in Cuba. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.576. Additionally, 31 CFR § 515.573(d) authorizes private foundations or research or educational institutes engaging in transactions authorized by § 515.576 to establish a physical presence in Cuba, such as an office. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.573(a).

Date Updated: September 29, 2026

Section 515.574 of the CACR contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are intended to provide support for the Cuban people, which include activities of recognized human rights organizations; independent organizations designed to promote a rapid, peaceful transition to democracy; and individuals and non-governmental organizations that promote independent activity intended to strengthen civil society in Cuba.  In accordance with NSPM-5 as issued June 16, 2017, OFAC amended this general license on November 8, 2017, to require that each traveler utilizing this authorization engage in a full-time schedule of activities that enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people's independence from Cuban authorities and that result in meaningful interactions with individuals in Cuba. This general license excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department's Cuba Restricted List. This general license also excludes lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210.  For a complete description of the scope of this prohibition, see 31 CFR § 515.210.  The traveler's schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule in Cuba.  An entire group does not qualify for this general license merely because some members of the group qualify individually.  For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.574.

Date Updated: September 29, 2026

Section 515.567(a) of the CACR contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to organization of and participation in amateur and semi-professional international sports federation competitions. Transactions incident to the organization of such competitions include marketing related to those specific events in Cuba.

OFAC will consider issuing specific licenses, on a case-by-case basis, for travel-related transactions and other transactions that are directly incident to participation in or organization of a public performance, clinic, workshop, athletic competition not covered by the general license in § 515.567(a), non-athletic competition, or exhibition in Cuba, subject to certain conditions.

OFAC excludes from this authorization direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the Cuba Restricted List. OFAC also excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210. For a complete description of the scope of this prohibition, see 31 CFR § 515.210. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.567.

Date Updated: September 29, 2026

Section 515.566 of the CACR contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to religious activities in Cuba. All persons subject to U.S. jurisdiction, including religious organizations located in the United States and members and staff of such organizations, are generally authorized to engage in travel-related transactions that are directly incident to engaging in religious activities in Cuba provided, among other things, that the travel must be for the purpose of engaging in a program of religious activities. This general license excludes direct and, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. This general license also excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210. For a complete description of the scope of this prohibition, see 31 CFR § 515.210. The traveler's schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule in Cuba. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.566.

Date Updated: September 29, 2026

No, persons subject to U.S. jurisdiction may not travel to Cuba to engage in "people-to-people" educational exchanges on an individual basis or, effective September 30, 2026, as part of a group.

However, § 515.565(c) includes a grandfathering provision, authorizing certain educational travel that was previously authorized under § 515.565(a). Specifically, travelers may still engage in group people-to-people travel for educational activities consistent with the authorization for educational travel (31 CFR § 515.565(b)) as the authorization existed on June 30, 2025 (when the 2026 NSPM-5 was issued) provided the traveler has already completed at least one travel-related transaction (such as purchasing a flight or reserving accommodation) prior to September 30, 2026. Any travel-related transactions under this grandfather provision, however, cannot involve either a direct or indirect financial transaction with entities or subentities on the State Department’s Cuba Restricted List. Please see FAQ 1274 for more information about how the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affected travel to Cuba for persons subject to U.S. jurisdiction.

Date Updated: September 29, 2026

On September 30, 2026, OFAC amended 31 CFR § 515.565(a) to restore particular requirements for authorized educational activities related to Cuba. As of September 30, 2026, the requirements related to a person's use of the educational activities- authorization depend on whether the person engaging in the activity is associated with an accredited U.S. undergraduate or graduate degree-granting academic institution.

Effective September 30, 2026, § 515.565(a)(1) authorizes accredited U.S. undergraduate or graduate degree-granting academic institutions and their faculty, staff, and students, to engage in the travel-related transactions set forth in 31 CFR § 515.560(c) and such additional transactions as are directly incident to the six categories of educational activities enumerated in § 515.565(a)(1). Among other educational activities, this general license authorizes, subject to conditions outlined in § 515.565(a)(1), faculty, staff, and students at accredited U.S. undergraduate or graduate degree-granting academic institutions to participate in a structured educational program in Cuba or to teach at a Cuban academic institution, as well as authorizes Cuban scholars to engage in certain educational activities in the United States. For a complete description of authorized educational activities related to accredited U.S. undergraduate or graduate degree-granting academic institutions, and the restrictions that apply, see § 515.565(a)(1).

Effective September 30, 2026, § 515.565(a)(2) authorizes persons subject to U.S. jurisdiction, including, for example, U.S. secondary schools, to engage in additional educational activities that are not authorized under § 515.565(a)(1), provided that: (1) any travel-related transactions pursuant to these authorizations take place under the auspices of an organization that is a person subject to U.S. jurisdiction (the "sponsoring organization"), and (2) all travelers are accompanied by a person subject to U.S. jurisdiction who is an employee, paid consultant, agent, or other representative of the sponsoring organization (subject to certain exceptions). These authorized transactions include the travel-related transactions set forth in § 515.560(c) and such transactions as are directly incident to the 12 categories of educational activities enumerated in § 515.565(a)(2). For example, under this general license, U.S. and Cuban universities may engage in academic exchanges and joint non-commercial academic research, and persons subject to U.S. jurisdiction may provide standardized testing services and certain internet-based courses to Cuban nationals. For a complete description of what this general license authorizes and the restrictions that apply, see § 515.565(a)(2).

Effective September 30, 2026, OFAC further amended § 515.565 to remove the authorization for group people-to-people educational travel.

Please note that the general license at § 515.565 excludes any direct or, effective September 30, 2026, indirect financial transaction with entities and subentities identified on the State Department's Cuba Restricted List. For a description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see § 515.209. This general license also excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210.

Date Updated: September 29, 2026

31 CFR § 515.564 (a)(1) contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to professional research in Cuba. Among other things, this general license authorizes, subject to conditions, professional research in Cuba relating to a traveler's profession, professional background, or area of expertise.

Effective September 30, 2026, OFAC amended § 515.564(a) to remove the previous license authorizing travel-related and other transactions incident to attendance at or organization of professional meetings or conferences in Cuba. However, specific licenses may be issued on a case-by-case basis for transactions related to such professional meetings. See FAQ 1275 for additional information on these changes.

Please note that § 515.564 excludes from its authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210. For a complete description of the scope of this prohibition, see § 515.210. § 515.564 also excludes from its authorization any direct or indirect financial transaction with an entity or subentity identified on the State Department’s Cuba Restricted List. For a complete description of the scope of this prohibition, see § 515.209.

The traveler's schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule of professional research or a full-time schedule of attendance at, or organization of, professional meetings or conferences, respectively. An entire group does not qualify for the general license merely because some members of the group qualify individually. For a complete description of what these general licenses authorize and the restrictions that apply, see § 515.564.

Date Updated: September 29, 2026

OFAC regulations generally authorize persons subject to U.S. jurisdiction and those sharing a dwelling with them as a family to visit a close relative in Cuba, including a close relative who is a Cuban national or a person ordinarily resident in Cuba, or to visit or accompany a close relative who is located in or traveling to Cuba pursuant to the authorizations in § 515.562 (official government business), § 515.563 (journalistic activity), § 515.564(a) (professional research), § 515.565(a)(1)(i) through (iv) and (vi) (educational activities), § 515.566 (religious activities), § 515.575 (humanitarian projects), or § 515.576 (activities of private foundations or research or educational institutes). A close relative is defined as any individual related to a person "by blood, marriage, or adoption who is no more than three generations removed from that person or from a common ancestor with that person." For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.339 and § 515.561. The authorizations contained within § 515.561 exclude direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209 or FAQ 735. 

Date Updated: September 29, 2026

Any travel-related arrangements that include direct or indirect financial transactions with entities and subentities that appear on the State Department's Cuba Restricted List will continue to be permitted, provided that those travel arrangements were initiated prior to the State Department’s addition of the entity or subentity to the list. Once the State Department adds an entity or subentity to the Cuba Restricted List, new direct or, effective September 30, 2026, indirect financial transactions with the entity or subentity are prohibited, unless authorized by OFAC or exempt. For a complete description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209.

Date Updated: September 29, 2026

Travel-related transactions are permitted by general or specific licenses for certain travel related to the 12 categories of activities identified in 31 CFR § 515.560(a). Those travel-related transactions permitted by general license, subject to specified criteria and conditions, include: family visits; official business of the U.S. government, foreign governments, and certain intergovernmental organizations; journalistic activity; professional research and professional meetings; educational activities; religious activities; athletic competitions by amateur or semi-professional athletes or athletic teams; support for the Cuban people; humanitarian projects; activities of private foundations or research or educational institutes; exportation, importation, or transmission of information or information materials; and certain authorized export transactions. Each person relying on a certain general authorization must retain specific records related to the authorized travel transactions. See §§ 501.601 and 501.602 of the Reporting, Procedures and Penalties Regulations for applicable recordkeeping and reporting requirements.

Effective September 30, 2026, OFAC amended § 515.564(a) to remove the authorization for persons subject to U.S. jurisdiction to travel to Cuba for purposes of attending or organizing professional meetings or conferences in Cuba. OFAC also amended § 515.565 to reinstate certain restrictions on authorized academic educational activities to require certain educational travel to occur under the auspices of an organization subject to the jurisdiction of the United States, and a representative of that sponsoring organization to accompany those travelers. Finally, OFAC removed the authorization for group people-to-people educational travel previously included in § 515.565. See FAQs 1274 and 1275 for more information on changes to travel-related authorizations under the Cuban Assets Control Regulations (CACR).

Furthermore, the CACR includes a prohibition at § 515.209 that restricts certain direct and, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department's Cuba Restricted List (CRL). For a description of the scope of the prohibition on direct and indirect financial transactions with entities or subentities on the CRL, and the restrictions and exceptions that apply, see § 515.209.

Additionally, § 515.210 prohibits any person subject to U.S. jurisdiction from lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property that the Secretary of State has identified as a property in Cuba that is owned or controlled by: the Cuban government; a prohibited official of the Government of Cuba, as defined in § 515.337; a prohibited member of the Cuban Communist Party, as defined in § 515.338; a close relative, as defined in § 515.339, of a prohibited official of the Government of Cuba, or a close relative of a prohibited member of the Cuban Communist Party, when the terms of the general or specific license expressly exclude such a transaction. The State Department maintains the Cuba Prohibited Accommodations List, which identifies the names, addresses, or other identifying details, as relevant, of properties identified as meeting such criteria.

Updated: September 29, 2026

The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV. One effect of subsection 1(a)(iii) is to require authorization before U.S. persons may engage in certain transactions regarding any equity interest in an entity owned 50 percent or more by the GOV. Subsequent to the issuance of E.O. 13835, OFAC received inquiries about how and whether subsection 1(a)(iii) of E.O. 13835 could affect the ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond. OFAC issued General License (GL) 5 on July 19, 2018, which removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.

General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license. Since that date, OFAC has extended the delay in effectiveness multiple times. Most recently, OFAC issued General License 5Z on September 16, 2026, which further delays the effectiveness of the authorization in GL 5 until November 5, 2026. Between October 24, 2019 and November 5, 2026 (the date the authorization in General License 5Z becomes effective), there is no authorization in effect that licenses against subsection 1(a)(iii) of E.O. 13835 applicable to the holders of the PdVSA 2020 8.5 percent bond. As a result, during such period, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.

To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply. OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.

Date Updated: September 16, 2026

Simultaneous Publish Test

GL 52C authorizes, subject to its conditions and exclusions, transactions prohibited by Executive Orders (E.O.s) 13884 or 13850 with Petróleos de Venezuela, S.A. (PdVSA) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, "PdVSA Entities"), by established U.S. entities. Transactions authorized by GL 52C include activities related to:

• the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan oil or petroleum products of Venezuelan-origin oil and petroleum products;
• the provision to Venezuela of diluent, goods, services, and technologies necessary for exploration, development, or production activities in the oil, gas, or petrochemical products sectors;
• entry into new investment contracts for exploration, development, or production activities in the oil, gas, or petroleum products sectors of Venezuela;
• the formation of new joint ventures or other entities in Venezuela related to such activities; and
• all transactions ordinarily incident and necessary to such activities, including the performance of commercial, legal, technical, safety, and environmental due diligence and assessments related to the foregoing.

GL 52C also authorizes individuals blocked pursuant to the Venezuela Sanctions Regulations (VSR) to execute and sign contracts authorized by GL 52C in their official capacity as officers, employees, or authorized representatives of PdVSA or PdVSA Entities.

Notably, GL 52C does not authorize transactions that would otherwise be prohibited by the VSR and associated Executive Orders, including E.O. 13808 and E.O. 13835, such as:

• transactions related to bonds and debt issued by PdVSA and its subsidiaries, including settlement of such bonds and debt;
• transactions involving equity interest in PdVSA and its subsidiaries, including the sale, transfer, assignment, or use as collateral of equity interests in PdVSA and its subsidiaries by the Government of Venezuela;
• transactions involving the transfer of equity interest in PDV Holding, CITGO Holding, or CITGO Petroleum Corp.;
• transactions to affect or alter the governance of PDV Holding, Inc., Citgo Holding, Inc., or CITGO Petroleum Corporation, including the appointment, removal, or replacement of any director, officer, or other corporate governance official; or
• transactions involving any other individuals or entities on the List of Specially Designated Nationals and Blocked Persons.

GL 52C also does not authorize:

• transactions that are not on commercially reasonable terms;
• payment in gold or the use of debt swaps;
• payments denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
• any transaction involving a person located in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled by or in a joint venture with such persons;
• transactions involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
• the unblocking of any property blocked pursuant to the VSR; or
• any transaction involving a blocked vessel.

Date Updated: September 14, 2026

Given that many of OFAC's licensing determinations are guided by U.S. foreign policy and national security concerns, OFAC often coordinates with the U.S. Department of State and other government agencies, such as the U.S. Department of Commerce, to make licensing determinations. Please note that such coordination does not eliminate the need for the applicant to comply with other provisions of 31 CFR chapter V and other applicable laws and regulations, including any aviation, financial, or trade requirements, of agencies other than OFAC. Such requirements may include the Export Administration Regulations, 15 CFR parts 730-774, administered by the Department of Commerce, and the International Traffic in Arms Regulations, 22 CFR parts 120-130, administered by the Department of State.

Date Updated: September 9, 2026

Applicants can check the status of their application through the OFAC Specific Licenses and Interpretive Guidance page on OFAC's website by selecting "View Application Status" and entering the case identification ("Case ID") number in the OFAC Licensing Portal. For more information on your status, please see OFAC's guide to Understanding an OFAC License Application Status. Applicants who opted to create an account can also view the status of their application(s) by logging in. For more information on how to find your Case ID number, see FAQ 1269.

OFAC will notify applicants via email as soon as a determination has been made on their application.

Date Updated: September 9, 2026

Applicants or other interested parties may request, at any time, reconsideration of a denied license application on the basis of changed circumstances or new facts. OFAC will reconsider such determinations for good cause, where the applicant has demonstrated changed circumstances or submitted additional relevant information not previously made available to OFAC.

If you submit a request for reconsideration of a specific license application, please clearly identify how circumstances have changed since your last application and the new information that was not included in your previous application.

To submit a specific license reconsideration request, visit the OFAC Specific Licenses and Interpretive Guidance page and submit a new application referencing the previous license denial.

Date Updated: September 9, 2026

OFAC encourages applicants to file an electronic license application, available via the OFAC Specific Licenses and Interpretive Guidance page on OFAC's website. It is essential to follow instructions and include all necessary information in your application, as detailed in the online application and the regulations. When applying for a license, provide a detailed description of the proposed transaction, including the names and addresses of any individuals or entities involved. For additional best practices for license applications, see the License Applications Quick-Reference Guide on OFAC's website. The OFAC Video Series also offers step-by-step guidance in "My Funds are Blocked, Now What?" and "Applying for a License to Release Blocked Funds."

Applicants can monitor the status of their applications online. For information on how to check the status of your specific license application, see FAQ 77. To learn more about the application review process see OFAC's License Applications Quick-Reference Guide: Understanding an OFAC License Application Status.

You also may contact the OFAC Licensing Hotline for specific license-related questions. Please note that the Licensing Hotline should not be used to submit license applications; applications should be submitted via the OFAC Licensing Portal. For general guidance on how to comply with OFAC-administered sanctions programs and tips for navigating OFAC's website, please submit a query to the OFAC Compliance Hotline.

For additional information on OFAC’s licensing process, please see 31 CFR § 501.801.

Date Updated: September 9, 2026

An OFAC license is an authorization from OFAC to engage in transactions that otherwise would be prohibited by U.S. sanctions administered by OFAC.

There are two types of OFAC licenses: general licenses and specific licenses.

General License: A general license authorizes certain categories of transactions that would otherwise be prohibited pursuant to a particular sanctions program. OFAC general licenses are public and are "self-executing," meaning that persons who determine their transactions meet the terms and conditions as described in the general license, do not require further authorization from OFAC. Some general licenses can be found within OFAC's implementing regulations for the relevant sanctions program, while other general licenses can be found on the relevant Sanctions Programs and Country Information page on OFAC's website.

Specific License: A specific license is a non-public document issued by OFAC to a particular individual or entity, authorizing a particular transaction in response to a license application. For guidance on how to apply for a specific license, please see 31 CFR § 501.801, the OFAC Specific Licenses and Interpretive Guidance page on OFAC's website, and the OFAC Licenses FAQ topic page on OFAC's website.

Please note that persons engaging in transactions pursuant to general or specific licenses must comply with all license terms, including conditions and recordkeeping and reporting requirements, as applicable.

Date Updated: September 9, 2026

Some OFAC sanctions programs that broadly prohibit transactions involving an entire jurisdiction have exemptions or general licenses for certain donated goods, such as humanitarian articles, to relieve human suffering. For information on the exemptions and general licenses under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC's website.

Where humanitarian assistance-related transactions are not exempt or authorized pursuant to a general license, OFAC has long had a favorable specific licensing policy of supporting these types of transactions as necessary and appropriate (For background on the difference between a general and specific license, please see FAQ 74). OFAC prioritizes requests for specific licenses to provide humanitarian assistance and endeavors to review such applications expeditiously. OFAC encourages applicants to submit applications online (via the OFAC Specific Licenses and Interpretive Guidance Application page on OFAC's website) and to include a brief description of the proposed activities, the sanctioned jurisdictions or persons involved (including persons that appear on OFAC's sanctions lists, such as the Specially Designated Nationals and Blocked Persons List (the "SDN List")), as well as any risk mitigation measures that will be used to prevent potential violations.

Date Updated: September 9, 2026

OFAC reviews each specific license application on a case-by-case basis, generally in the order in which they are received. The review process for each license application may vary, which will affect the length of the review. For example, in some instances, OFAC may require additional information from the applicant, and in others, OFAC may need to consult with other U.S. government agencies. Additionally, an increase in the volume of licensing applications may lead to longer wait times. Following the license application guidelines on the OFAC Specific Licenses and Interpretive Guidance page on OFAC's website, including OFAC's Best Practices for License Applicants, and providing all required information, can help accelerate the review process.  

Applicants can check their application's progress from the OFAC Specific Licenses and Interpretive Guidance page on OFAC's website by selecting "View Application Status" and entering the case identification ("Case ID") number in the OFAC Licensing Portal.  

Date Updated: September 9, 2026

OFAC itself does not seize or hold blocked funds. To comply with U.S. sanctions regulations administered by OFAC, U.S. financial institutions are required to block or "freeze" certain property (e.g., funds, accounts) in their possession or control and report such blocked property to OFAC. Even though property blocked pursuant to OFAC-administered sanctions is not held by OFAC (or other offices of the U.S. Department of the Treasury), authorization from OFAC is required for U.S. financial institutions to release such blocked property.

If you believe your funds or other property have been blocked due to OFAC-administered sanctions and you want the funds released (i.e., unblocked), you should first contact your financial institution to confirm the funds are in fact blocked pursuant to OFAC-administered sanctions. You may want to ask to speak to someone who handles sanctions compliance for the bank, likely in the bank's headquarters rather than at a branch.

If confirmed, OFAC encourages you to file a specific license application via the OFAC Specific Licenses and Interpretive Guidance page on OFAC's website. To complete this application, you will also need your financial institution to identify the financial institution—which may be different than yours—that filed the required blocking report with OFAC. OFAC generally does not process requests for the release of blocked funds where a corresponding blocking report has not been filed.

You also will need to provide a detailed description of the funds that are blocked, the names and addresses of any persons involved in the transaction or possession of the funds, and copies of supporting documentation (e.g., payment or funds transfer instructions). For further information on specific licenses, including how to apply for one, please see 31 CFR § 501.801, the OFAC Specific Licenses and Interpretive Guidance page on OFAC's website, and FAQ 74.  

For more information on blocked funds, please see "My Funds are Blocked, Now What?" on the OFAC Video Series page on OFAC's website.

Date Updated: September 9, 2026

OFAC encourages anyone who is aware of possible violations of OFAC-administered sanctions to report them to OFAC through OFAC's Disclosure Portal. In considering any enforcement action, OFAC looks at the totality of the circumstances surrounding any possible violation, including whether a matter was voluntarily self-disclosed. OFAC considers voluntary self-disclosure a mitigating factor that, pursuant to OFAC's Economic Sanctions Enforcement Guidelines, may result in a reduction in the base amount of any possible civil penalty. Benefits may also include a greater likelihood of avoiding a financial penalty.  

OFAC's Enforcement Guidelines explain what constitutes a voluntary self-disclosure for purposes of receiving a reduction in the base penalty or penalty mitigation. Among other factors, the guidelines state that, in addition to notification of an apparent violation, a voluntary self-disclosure must include, or be followed within a reasonable period of time by, a report of sufficient detail to afford OFAC a complete understanding of an apparent violation's circumstances. When such a report is not included with an initial notification, OFAC will generally expect such a report within 180 days after the initial notification. A voluntary self-disclosure also may evidence the extent of an organization's cooperation — an important factor OFAC considers in determining the appropriate enforcement response.  

All submissions to the Disclosure Portal should conform to OFAC's Production Submission Standards, which detail OFAC technical standards for formatting electronic document production.  

For resources related to OFAC enforcement, please see OFAC's Civil Penalties and Enforcement Information page. For information on an effective sanctions compliance program, see OFAC's Framework for OFAC Compliance Commitments.

In addition, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) maintains a whistleblower incentive program for violations of OFAC-administered sanctions, in addition to violations of the Bank Secrecy Act. Individuals located in the United States or abroad who provide information may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding $1,000,000. The U.S. Department of Justice (DOJ) and the U.S. Department of Commerce's Bureau of Industry and Security (BIS) also maintain their own disclosure programs, including for violations of U.S. sanctions and export controls laws.

Date Updated: September 9, 2026

When attempting to verify or disqualify potential matches to individuals or entities on OFAC's sanctions lists, organizations should follow their own sanctions compliance policies and procedures for investigating potential matches.  OFAC recommends that such procedures include the following steps: 

Step 1: Determine whether the "alert" or "hit" matches against one of OFAC's sanctions lists (or otherwise involves an OFAC sanctions program) or matches against a list maintained by other government agencies or other organizations.

OFAC maintains the Specially Designated Nationals and Blocked Persons List (SDN List), as well as several other sanctions lists that have different associated prohibitions. OFAC also administers sanctions programs that broadly prohibit activity involving certain regions, countries, or governments. See the Introduction to the Office of Foreign Assets Control guide for more information on OFAC and its sanctions, and see the Sanctions Programs and Country Information page on OFAC's website for information on specific OFAC sanctions programs.

Screening tools often screen against OFAC's sanctions lists as well as lists of potentially restricted persons maintained by other government agencies, screening software vendors, or internal lists maintained by the screening tool user. Some examples of non-OFAC lists maintained by other government agencies include the U.S. Department of Commerce's Bureau of Industry and Security (BIS) Entity List, the Federal Bureau of Investigation's (FBI) Most Wanted List, and the U.S. State Department's Debarred Parties List.

If the potential match is against a list maintained by another agency, contact the relevant agency that maintains the list. OFAC does not provide guidance on potential matches unrelated to OFAC sanctions. If you are unsure which list the match relates to, consider escalating the potential match to your supervisor, compliance department, or the screening service vendor (if applicable).

Step 2: If the "alert" or "hit" involves OFAC sanctions, next determine whether it involves a potential match to a name on one of OFAC's sanctions lists; a country, region, or government targeted by OFAC sanctions; or any other non-listed sanctions target.

If there is a potential match to a name on one of OFAC's sanctions lists, proceed to Step 3. If the alert implicates some other potential nexus to OFAC sanctions, such as broad jurisdiction-based sanctions (e.g., targeting Iran), government or regime sanctions (e.g., against the Government of Cuba), or sanctions targeting another unlisted entity blocked by operation of law (see FAQs on OFAC's 50 Percent Rule), consider escalating the issue to your supervisor or compliance department before taking action because OFAC regulations may prohibit the transaction or require blocking. Carefully review the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC's website to determine the appropriate action. Keep in mind that certain transactions or activity may be authorized or exempted from OFAC sanctions. For example, some sanctions programs authorize transactions involving personal remittances, subject to certain restrictions.    

Step 3: If the "alert" or "hit" involves a potential match to a name or alias on one of OFAC's sanctions lists, evaluate the quality of the potential match.

Start by reviewing the complete sanctions list entry for the potential match using your organization's in-house or third-party screening software, or OFAC's Sanctions List Service, or OFAC's Sanctions List Search Tool (Watch our OFAC Basics video: Sanctions List Search for guidance on how to use the tool). 

OFAC's list entries include additional information you may use for this step, such as full names, former names, known aliases, nationalities, passport, tax ID, national identification numbers, place of birth, date of birth, business registration numbers, or known addresses. OFAC's enhanced list data formats include additional information such as date of designation, and names and aliases in non-Latin character sets.

Some listed aliases may be classified by OFAC as "weak aliases," and your screening tool may exclude these aliases as part of a risk-based decision. For additional information, see OFAC's answers to frequently asked questions on the Weak Aliases topic page on OFAC's website.

Many potential matches identified through screening are false positives. For example, you may receive an alert when an individual or entity has a similar name or alias to a vessel identified on one of OFAC's lists.

To verify or disqualify a potential match, compare all of the details in the OFAC listing with the information available to you about the data in your transaction or activity that led to the "alert" or "hit." This may require gathering additional information from parties involved in the transaction or activity, such as a birth certificate, driver's license, or a business's corporate registration documentation.

Consider how much of the listed person's information matches against information for the party in your transaction or activity. If there are very few similarities between the listed party's information and information for the party in your transaction or activity, you may not have a valid match. For example, does only the first or last name match the listed name or aliases? Does the party to your transaction or activity have a different date of birth, identification number, or nationality? Is the listed address distinct from the address of the party to your transaction or activity? For address matches, note that multiple businesses may be registered or located at the same address, so an exact match on an address alone, may not be sufficient to indicate a potential match. Also consider the nature of the sanctioned person. For example, do you have a close or exact name match, but the sanctioned person is a well-known figure (e.g., sanctioned government leader) and open-source reporting and photographs do not match information (e.g., passport or driver's license) provided by the person involved in your transaction? If after you review available information, you can reasonably determine the match is not valid, then you may proceed with the transaction or activity.  

Alternatively, if multiple pieces of information in OFAC's listing match the person involved in your transaction or activity (e.g., name and date of birth for individuals or organization name and location for entities), proceed to Step 4.

Step 4: Determine next steps required for a valid match.

If you have identified an exact match, or a close match with multiple similarities (e.g., a full name, date of birth, and country location matching, but different city locations), and—after gathering and reviewing all available information—you have not identified any information that disqualifies the potential match, follow your organization's sanctions compliance procedures for likely matches. OFAC recommends organizations assess all the information available to make a risk-based decision about the validity of a potential match in line with the organization's policies, procedures, risk profile, and regulator guidance (if applicable).

Once you determine you have identified a valid match, you should review the relevant sanctions regulations and other information available on OFAC's website to evaluate whether any OFAC authorizations or exemptions apply to the transaction or activity. If the transaction or activity is exempt or authorized by OFAC via a general or specific license, your organization may process the transaction or proceed with the activity consistent with your organization's risk tolerance and internal policies. If you determine that relevant authorizations or exemptions do not apply, proceed to Step 5.

Step 5: Determine whether you are required to block the property, or whether you are required to reject the transaction or stop certain activity.

If OFAC sanctions require blocking, you must freeze the assets or property pursuant to OFAC regulations. For example, blocked funds should be placed into a qualifying, segregated, interest-bearing account located at a federally insured financial institution in the United States, from which only OFAC-authorized debits may be made. See the relevant sanctions regulations for more information on holding funds in blocked accounts. If OFAC sanctions prohibit the transaction or activity, but there is no blockable interest (i.e., no SDN or other blocked person is involved), the transaction must be rejected (i.e., the activity should not proceed). For more information, see OFAC's FAQs about blocking and rejecting transactions.

Refer to the chart below for general guidance on circumstances where each action may be appropriate. Each OFAC sanctions program is unique, so always check the applicable regulations to confirm the appropriate action.

Step 6: Report valid matches to OFAC and maintain required records.

Organizations should keep complete, accurate records detailing the steps taken to investigate the potential match and the information relied upon to ultimately determine whether the potential match was valid. OFAC may request these records in accordance with 31 C.F.R. § 501.602.

If you block property or reject transactions or activity due to OFAC sanctions, you must report the action to OFAC within 10 business days (see 31 C.F.R. §§ 501.603 and 501.604) and retain related records in accordance with OFAC's recordkeeping requirements (see 31 C.F.R. § 501.601). Please see OFAC's answers to frequently asked questions on Filing Reports with OFAC for more information.

You may contact the OFAC Compliance Hotline for questions related to this guidance. Please note that OFAC does not confirm potential matches or false positives to our sanctions lists and instead encourages organizations to make risk-based determinations consistent with the guidance above.

Date Updated: September 9, 2026

Simultaneous Publish Test

No, provided that non-U.S. persons comply with certain conditions outlined in GLs 46D, 51D, and 52B as described below. Subject to certain conditions, GLs 46D, 51D, and 52B authorize established U.S. entities to engage in certain transactions involving Petróleos de Venezuela, S.A. (PdVSA), as well as certain transactions with the Government of Venezuela, including Carbones del Zulia S.A. (Carbozulia), PdVSA, or CVG Compania General de Mineria de Venezuela CA (Minerven) that are ordinarily incident and necessary to, among other activities, the exportation, sale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin oil, petrochemical products, minerals (including gold), or coal. Generally, non-U.S. persons do not risk exposure to U.S. sanctions for engaging in transactions authorized under GLs 46D, 51D, and 52B — such as transacting with PdVSA or importing Venezuelan-origin oil, petrochemical products, minerals, or coal, into a third country — provided that:

• The non-U.S. entity was organized under the laws of a third country on or before January 29, 2025;
• Any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, is made into the Foreign Government Deposit Funds, as specified in Executive Order 14373 of January 9, 2026, or any other account as instructed by the U.S. Department of the Treasury;
• The payment terms are commercially reasonable;
• The payment terms do not involve debt swaps, and are not denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
• The transaction does not involve a person located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons;
• The transaction does not involve an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
• The transaction does not involve a blocked vessel; and
• With respect to GL 51D, the transaction does not involve the processing or refining of Venezuelan-origin coal or minerals, including gold, in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or the People’s Republic of China.

These conditions are designed to ensure that transactions involving the Government of Venezuela, including Carbozulia, PdVSA, Minerven, or Venezuelan-origin oil, petrochemical products, minerals, or coal occur through legitimate and authorized channels, consistent with efforts to restore prosperity, safety, and security to Venezuela. Non-U.S. persons who continue to transact with PdVSA or Minerven, or import Venezuelan-origin oil, petrochemical products, minerals including gold, or coal, without complying with the above conditions risk being designated themselves, including for providing financial, material, or technological support to blocked persons, being responsible for or complicit in a transaction involving deceptive practices or corruption and the Government of Venezuela, or operating in the gold or oil sectors of the Venezuelan economy.

Please note that GL 52B contains additional restrictions on engaging in certain transactions prohibited by other Venezuela-related Executive orders, such as transactions related to bonds and debt issued by PdVSA, as well as on the entry into a settlement agreement or the enforcement of any lien, judgment, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property of any persons blocked pursuant to the Venezuela Sanctions Regulations.

Please see FAQ 1226 for the definition of “Venezuelan-origin oil,” which includes petroleum products.

Please see FAQ 1232 for what OFAC considers “commercially reasonable terms.”

Please see FAQ 1239 for information on how to make authorized payments to the Foreign Government Deposit Funds, as specified in E.O. 14373.

Date Updated: September 02, 2026

No. The dispute resolution requirement in certain Venezuela General Licenses (GL), (e.g., 46D, 47B, 48B, 50C, 51C, 52B, 54B, and 61A) only requires that contracts governing transactions with the Government of Venezuela (GOV) or certain other blocked persons (e.g., Petróleos de Venezuela, S.A. (PdVSA) in GL 52B or CVG Compañía General de Minería de Venezuela CA in GL 51C) specify that the dispute resolution proceedings relating to the contract occur in the United States, the United Kingdom, France, or Singapore. This requirement does not apply to indirect parties or indirect counterparties involved in transactions authorized by these GLs, such as downstream transactions involving the provision of shipping, insurance, or other services to an entity engaged in a transaction involving PdVSA. For example, this provision would not apply to a contract between an insurance provider and an established U.S. entity engaged in a transaction with PdVSA to purchase Venezuelan-origin oil (though it would apply to the contract between the U.S. entity and PdVSA).

Date Updated: August 27, 2026

Simultaneous Publish Test

No. The United States no longer maintains comprehensive sanctions on Syria, effective July 1, 2025, following the issuance of E.O. 14312. You may send U.S.-origin food or medicine to Syria without a specific license from OFAC.

The Department of Commerce maintains jurisdiction over the export of certain items to Syria. Please contact the Department of Commerce for more specifics on export controls involving Syria.

Date Updated: August 24, 2026

Simultaneous Publish Test

Yes. All Syrian financial institutions, including the Central Bank of Syria, were removed from OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List) on June 30, 2025.

Effective July 1, 2025, U.S. persons are not prohibited from providing financial services to Syria, processing payments on behalf of third country financial institutions involving Syrian financial institutions, or conducting transactions with the new Government of Syria and Syrian financial institutions, provided that none of the involved parties are on the SDN List. This includes establishing correspondent banking relationships with Syrian financial institutions. In line with the lifting of Syria sanctions, the Financial Crimes Enforcement Network issued exceptive relief in late May 2025 to permit U.S. financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria. OFAC strongly encourages financial institutions to employ a risk-based sanctions compliance program and update it as appropriate in consideration of new business lines. 

Date Updated: August 24, 2026

Simultaneous Publish Test

E.O. 14312 removes sanctions on Syria, effective July 1, 2025, while maintaining sanctions on Bashar al-Assad and certain other destabilizing regional actors. Specifically, the E.O. revokes the following six E.O.s that form the foundation of the Syrian Sanctions Program and terminates the national emergency underlying those E.O.s, effective July 1, 2025:

• E.O. 13338 of May 11, 2004;
• E.O. 13399 of April 25, 2006;
• E.O. 13460 of February 13, 2008;
• E.O. 13572 of April 29, 2011;
• E.O. 13573 of May 18, 2011; and
• E.O. 13582 of August 17, 2011.

As a result, as of July 1, 2025, the economic sanctions administered by OFAC that constitute the Syria Sanctions Program are no longer in effect. Persons blocked solely pursuant to the above E.O.s were removed from OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), and all property and interests in property of such persons are unblocked. On August 26, 2025, OFAC removed the Syrian Sanctions Regulations from the Code of Federal Regulations. Pending or future OFAC investigations or enforcement actions related to apparent violations of the Syrian Sanctions Regulations that occurred prior to July 1, 2025, may still be carried out.

Additionally, E.O. 14312 preserves and expands OFAC’s ability to target Bashar al-Assad and his associates, human rights abusers, captagon drug traffickers, and other destabilizing regional actors, by further amending E.O. 13894. Concurrently with the issuance of E.O. 14312, OFAC designated 139 persons who were previously designated under the Syrian Sanctions Regulations pursuant to E.O. 13894, as further amended, or other OFAC authorities.

Consistent with the guidance contained in E.O. 14312, the U.S. government took the following steps:

• On July 8, 2025, the State Department rescinded Hayat Tahrir al-Sham’s (HTS) designation as a Foreign Terrorist Organization, and on August 24, 2026, HTS was removed as a Specially Designated Global Terrorist organization from the SDN List. As a result, General License (GL) 25, which authorized certain transactions that could otherwise have been prohibited due to the role of HTS in the Syrian government, is no longer necessary, and OFAC has revoked the general license.
• On December 18, 2025, the President signed legislation repealing the Caesar Act, removing the threat of mandatory Caesar Act sanctions for foreign persons providing support to the Government of Syria and engaging in certain transactions involving Syrian industry, including the infrastructure and energy sectors.
• On August 24, 2026, the Secretary of State rescinded Syria’s SST designation.

Date Updated: August 24, 2026

Yes. OFAC's designation of Nobitex, Wallex, Bitpin, Ramzinex, Aban Tether, or any digital asset exchange pursuant to Executive Order (E.O.) 13902 for operating in the Iranian financial sector means that foreign financial institutions and other non-U.S. persons who transact with these exchanges may also face sanctions under E.O. 13902 or other Iran-related authorities. For example, pursuant to E.O. 13902, OFAC has authority to:

1. Designate persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of any digital asset exchange designated pursuant to E.O. 13902; or
2. Prohibit or impose strict conditions on correspondent account or payable-through account opening or maintenance by foreign financial institutions that have knowingly conducted or facilitated any significant financial transaction for or on behalf of any digital asset exchange designated pursuant to E.O. 13902.

Foreign financial institutions may be exposed to statutory sanctions for engaging in significant financial transactions with any designated Iranian financial institutions, including Nobitex, Wallex, Bitpin, Ramzinex, and Aban Tether, pursuant to the National Defense Authorization Act of Fiscal Year 2012. Please see FAQ 174 for more information.

For more information on Iranian digital asset exchanges being blocked under OFAC sanctions, please see FAQ 1250.

Date Updated: August 07, 2026

Directive 4 under Executive Order (E.O.) 14024, "Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation," as amended (Russia-related Sovereign Transactions Directive), prohibits the following activities by U.S. persons: any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities (collectively, "Directive 4 entities"). As noted in FAQ 1002, this includes both direct and indirect transactions.

OFAC issued the Russia-related Sovereign Transactions Directive with the explicit aim of preventing the Government of the Russian Federation from leveraging these institutions and their holdings of international reserves in ways that would undermine the impact of U.S. sanctions. Information currently available to OFAC suggests so-called "exit taxes" imposed by the Government of the Russian Federation involve payments to Directive 4 entities. Consequently, U.S. persons whose divestment from the Russian Federation will involve the payment of such an exit tax require a specific license from OFAC prior to the payment of such tax, unless otherwise authorized by OFAC.

GL 13R authorizes U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications involving Directive 4 entities that would otherwise be prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons' day-to-day operations in the Russian Federation. Payment of exit taxes is not considered ordinarily incident and necessary to day-to-day operations in the Russian Federation and, thus, is not authorized under GL 13R.

Therefore, U.S. persons whose divestment of assets in the Russian Federation will involve a payment of such an "exit tax" should seek a specific license from OFAC. Such persons may submit a request for a specific license with OFAC's Licensing Division online at https://ofac.treasury.gov/ofac-license-application-page. License applications related to these payments should include information regarding the amount of the exit tax, the amount of ongoing taxes that would otherwise be paid to the Government of the Russian Federation should divestment not occur, the impact of a failure to pay the tax on the employees of the exiting company, the specific economic activity in Russia of the exiting company, and the impact on the Russian Federation of the divestment. OFAC will expedite its review of such requests, which will be evaluated on a case-by-case basis.

While OFAC is aware that the Commission established by the Russian Federation to review such divestments may include individuals from entities subject to the Russia-related Sovereign Transactions Directive or individuals listed on the Specially Designated Nationals and Blocked Persons List, U.S. persons do not need to seek authorization from OFAC for their Russian buyers to submit an application to the Commission regarding a divestment transaction.

Date Updated: July 08, 2026

OFAC issued Russia-related General License (GL) 132 to authorize transactions involving the Paks II civil nuclear power plant project in Hungary, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive.

OFAC issued Russia-related General License (GL) 115C to authorize civil nuclear energy-related transactions, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive.

OFAC issued GL 13P to authorize U.S. persons to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons' day-to-day operations in the Russian Federation. For further information on the types of transactions authorized by GL 13P, see FAQ 1118.

OFAC also issued GL 14, authorizing certain transactions involving any Directive 4 entity where the Directive 4 entity's sole function in the transaction is to act as an operator of a clearing and settlement system. GL 14 does not authorize any transfer of assets to or from any Directive 4 entity, or any transaction where a Directive 4 entity is either a counterparty or beneficiary to the transaction. In addition, GL 14 does not authorize any debit to an account on the books of a U.S. financial institution of any Directive 4 entity. See FAQ 1003.

Note that GL 13P, GL 14, GL 115C, and GL 132 continue to authorize against the Russia-related Sovereign Transactions Directive.

Date Updated: January 06, 2026

In line with G7 efforts to reduce Russian revenues from energy, on January 10, 2025, Treasury issued a determination pursuant to Executive Order (E.O.) 14071 prohibiting petroleum services to Russia. See The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition on Petroleum Services ("the Petroleum Services Determination"). This determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, to any person located in the Russian Federation of petroleum services. The Petroleum Services Determination took effect at 12:01 a.m. eastern standard time on February 27, 2025. See FAQ 1217 for additional information.

OFAC expects to issue regulations defining petroleum services to include services related to the exploration, drilling, well completion, production, refining, processing, storage, maintenance, transportation, purchase, acquisition, testing, inspection, transfer, sale, trade, distribution, or marketing of petroleum, including crude oil and petroleum products, as well as any activities that contribute to Russia's ability to develop its domestic petroleum resources, or the maintenance or expansion of Russia's domestic production and refining. This would include services related to natural gas as a byproduct of oil production in Russia.

On October 22, 2025, OFAC issued GL 124A. In addition to continuing to authorize transactions prohibited by the Petroleum Services Determination related to the Caspian Pipeline Consortium (CPC) and Tengizchevroil, GL 124A also authorizes otherwise prohibited transactions related to the CPC and Tengizchevroil involving Lukoil, Rosneft, or any entity in which Lukoil or Rosneft owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. Additionally, on December 17, 2025, OFAC issued GL 55E, which extends authorizations for certain activities related to the Sakhalin-2 project that would otherwise be prohibited by the Petroleum Services Determination until June 18, 2026.

The Petroleum Services Determination does not apply to (1) any petroleum services related to isotopes derived from petroleum manufacturing that are used for medical, agricultural, or environmental purposes, such as Carbon-13; (2) certain covered services related to the maritime transport of crude oil and petroleum products of Russian Federation origin purchased at or below the relevant price cap; and (3) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person. See FAQ 1217 for additional information related to price cap related exclusions of the Petroleum Services Determination.

Date Updated: December 17, 2025

Treasury remains focused on counteracting activity that involves sanctions evasion or third-country support to Russia's military-industrial base. At the same time, legitimate humanitarian activity and agricultural and medical trade are not the target of our sanctions. Accordingly, FFIs may continue to conduct or facilitate any transaction(s) or provide any service related to activities that are otherwise authorized or exempted under the Russian Harmful Foreign Activities Sanctions program. Foreign persons do not risk the imposition of sanctions for engaging in transactions authorized for U.S. persons under General Licenses issued under the Russian Harmful Foreign Activities Sanctions program.

FFIs may continue to rely on Treasury's existing authorizations in place for transactions related to agricultural commodities, medicine, medical devices and related replacement parts, components, or software updates, the Coronavirus Disease 2019 (General License (GL) 6D), certain civil nuclear energy-related transactions (GLs 115C and 132), certain transactions in support of non-governmental organizations (GL 27), official business of third-country diplomatic or consular missions located in the Russian Federation (GL 20), certain transactions and official business of certain international organizations and entities by employees, grantees, or contractors thereof (31 CFR 587.510). Additionally, the importation or exportation of information or informational materials and transactions ordinarily incident to travel to or from any country are exempt under the International Emergency Economic Powers Act (IEEPA).

See OFAC's Advisory to Foreign Banks on Russia Sanctions Risks for additional guidance.

Date Updated: December 17, 2025

The determination made on February 24, 2023 pursuant to Executive Order (E.O.) 14024 authorizes sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy. Non-U.S. persons may also be exposed to sanctions for activities with persons blocked pursuant to E.O. 14024 (see FAQ 980), including persons blocked following a determination that such persons operate or have operated in the metals and mining sector.

However, OFAC does not intend to target persons for operating in the metals and mining sector where the provision of goods or services is solely for the safety and care of personnel, protection of human life, prevention of accidents or injuries, maintenance or repair necessary to avoid environmental or other significant damage, or activities related to environmental mitigation or remediation. Examples of such goods include personal protective equipment, safety devices, ventilation systems, and alarm systems; examples of such services include rescue and accident response services, cleaning, safety inspections, and services necessary for use of the goods described above.

In addition, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under E.O. 14024 for engaging in transactions with blocked persons, including in the metals and mining sector, where those transactions would not require a specific license if engaged in by a U.S. person. For example, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions for engaging in transactions in the metals and mining sector if such transactions would be authorized for U.S. persons by General License (GL) 115C (authorizing certain civil nuclear energy-related transactions) or by GL 6D (authorizing certain transactions related to the production, manufacturing, sale, transport, or provision of medicine or medical devices, including certain industrial isotopes used in nuclear medicine, among other things).

Date Updated: December 17, 2025

The Russia-related CAPTA Directive prohibits U.S. financial institutions from: (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive; and (ii) the processing of transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive. Please see the Russia-related CAPTA Directive for the definition of the terms "U.S. financial institution" and "foreign financial institution" for purposes of this directive. Please see FAQ 969 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive.

Annex 1 to the Russia-related CAPTA Directive lists the foreign financial institutions determined to be subject to the prohibitions as of March 26, 2022. Foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including the foreign financial institutions listed in Annex 1, can be found on the Office of Foreign Assets Control's (OFAC) List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List). Relevant entries on the CAPTA List will denote when a foreign financial institution became subject to the prohibitions of the Russia-related CAPTA Directive, as well as when the prohibitions of the Russia-related CAPTA Directive come into effect with respect to that foreign financial institution.

The below table identifies the dates the prohibitions of the Russia-related CAPTA Directive take effect for (i) foreign financial institutions listed in Annex 1 to the Russia-related CAPTA Directive, and (ii) foreign financial institutions otherwise determined to be subject to its prohibitions and added to the CAPTA List.

U.S. financial institutions must close any correspondent or payable-through account maintained for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, by the relevant effective date. Separately, as of the relevant effective date, U.S. financial institutions may not process transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, and must reject such transactions unless exempt or authorized by OFAC.

Accordingly, after the relevant effective date, U.S. financial institutions must reject any transaction involving a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive or involving that foreign financial institution's property or interests in property. This includes rejecting transactions related to any securities (including depositary receipts) issued by a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including secondary market trading. By virtue of the prohibition on the processing of transactions for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, U.S. financial institutions are also prohibited from engaging in transactions with a covered foreign financial institution in connection with the foreign financial institution's role as a local custodian for depositary receipt issuances.

The Russia-related CAPTA Directive does not impose blocking sanctions and, thus, does not require U.S. financial institutions (or other U.S. persons) to block the assets of foreign financial institutions determined to be subject to the prohibitions of this directive. However, U.S. persons should be aware that foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024 or E.O. 13662.

OFAC has issued several Russia-related general licenses (GLs) authorizing certain transactions involving the foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive, including:

• GL 6D: authorizing transactions related to (1) the production, manufacturing, sale, or transport of agricultural commodities, agricultural equipment, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices; (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19); or (3) ongoing clinical trials and other medical research activities;
• GL 7A: authorizing overflight payments, emergency landings, and air ambulance services;
• GL 27: authorizing transactions in support of nongovernmental organizations' activities; and
• GL 115C: authorizing certain transactions related to civil nuclear energy.
• GL 132: authorizing certain transactions involving Paks II civil nuclear power plant.

On March 1, 2022, OFAC issued the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), which incorporate GL 5 in section 587.510 of the RuHSR.

For additional information, please see FAQs 977, 978, 979, 981, 982 and 990.

Date Updated: December 17, 2025

Treasury took expansive sanctions actions related to Russia's financial services sector in February 2022 as detailed below.

• Financial services sector determination. On February 22, 2022, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination pursuant to E.O. 14024 that authorizes sanctions against persons determined to operate or to have operated in the financial services sector of the Russian Federation economy.
• Correspondent or payable-through account and payment processing prohibitions. On February 24, 2022, the Office of Foreign Assets Control (OFAC) issued 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), which prohibits U.S. financial institutions from: (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive; and (ii) the processing of transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive. Annex 1 to the Russia-related CAPTA Directive identifies Public Joint Stock Company Sberbank of Russia and other foreign financial institutions owned 50 percent or more by this bank as subject to these prohibitions, which become effective on March 26, 2022 (see FAQs 967, 968, 969, 970, 971, 972 and 973).
• Blocking certain Russian financial institutions. OFAC designated specified Russian financial institutions pursuant to E.O. 14024, including the State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), VTB Bank Public Joint Stock Company, Public Joint Stock Company Bank Financial Corporation Otkritie, Promsvyazbank Public Joint Stock Company, Sovcombank Open Joint Stock Company, Joint Stock Commercial Bank Novikombank, and several of these financial institutions' subsidiaries. As a result, all property and interests in property of these entities in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked and must be reported to OFAC. In addition, all property and interests in property of any entity that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Accordingly, U.S. persons, including U.S. financial institutions, are prohibited from transacting with these entities unless exempt or authorized by OFAC (see FAQs 974, 975, 977, 978, 979, 980, 981, and 982).
• Expanding sovereign debt prohibitions to include the secondary market. On February 22, 2022, OFAC issued Directive 1A under E.O. 14024, "Prohibitions Related to Certain Sovereign Debt of the Russian Federation" (Russia-related Sovereign Debt Directive), replacing and superseding Directive 1 under E.O. 14024 of April 15, 2021, to extend existing sovereign debt prohibitions to cover participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (see FAQs 888, 889, 890, 891, 965, and 983).
• New debt and equity restrictions involving certain Russia-related entities. On February 24, 2022, OFAC imposed additional debt and equity restrictions involving Russia-related entities by issuing Directive 3 under E.O. 14024, "Prohibitions Related to New Debt and Equity of Certain Russia-related Entities" (Russia-related Entities Directive), to prohibit certain dealings by U.S. persons, or within the United States, in new debt of longer than 14 days maturity or new equity of Russia-related entities determined to be subject to the prohibitions of the Russia-related Entities Directive. OFAC determined on February 24, 2022 that the entities listed in Annex 1 to the Russia-related Entities Directive, which include certain major Russian state-owned enterprises and large privately owned financial institutions, are subject to the prohibitions of this directive for new debt or equity issued on or after March 26, 2022 (see 983, 984, 985, 986, 987, 988 and 989).
• General Licenses (GLs). OFAC issued several Russia-related GLs authorizing certain transactions otherwise prohibited by E.O. 14024 (see FAQs 974, 975, 977, 978, 979, 981, 982, and 990).
• New restrictions on sovereign transactions. On February 28, 2022, OFAC issued Directive 4 under E.O. 14024, "Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation" (Russia-related Sovereign Transactions Directive) to prohibit U.S. persons from engaging in any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities (see FAQs 998 – 1003).

Date Updated: June 27, 2025

The Office of Foreign Assets Control (OFAC) has issued several authorizations related to U.S. and third-country diplomatic or consular missions operating in or outside of Russia and Russian diplomatic or consular missions operating abroad.

Russian Diplomatic or Consular Missions, Wherever Located: Russia-related General License (GL) 53A authorizes, subject to certain conditions, U.S. persons to engage in all transactions ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation where the transactions are prohibited by Executive Order (E.O.) 14024 and involve Gazprombank, or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest, or are prohibited by Directive 4 under E.O. 14024, "Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation."

U.S. Diplomatic or Consular Missions in Russia: The Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), authorize all transactions prohibited by the RuHSR that are for the conduct of the official business of the United States Government by employees, grantees, or contractors thereof. (See § 587.509). This authorization extends to the official business of U.S. diplomatic or consular missions. Additionally, E.O. 14024 exempts transactions for the official business of the United States Government conducted by its employees, grantees, and contractors from the prohibitions of the order.

Third-Country Diplomatic or Consular Missions in Russia: Russia-related GL 20 authorizes, subject to certain conditions, U.S. persons to engage in all transactions ordinarily incident and necessary to the official business of third-country diplomatic or consular missions located in the Russian Federation that are prohibited by E.O. 14024 or section 1(a)(iv) of E.O. 14068.

Third-Country Diplomatic or Consular Mission Outside of Russia: Russia-related General License (GL) 119 authorizes, subject to certain conditions, all transactions ordinarily incident and necessary to the official business of diplomatic or consular missions located outside of the Russian Federation that are prohibited by E.O. 14024 and involve Gazprom Neft, or any entity in which Gazprom Neft owns, directly or indirectly, a 50 percent or greater interest through 12:01 a.m. eastern standard time, February 27, 2025.

As a general matter, transactions that are "ordinarily incident and necessary" to the official business of a diplomatic or consular mission, whether third-country or Russian, include standard foreign diplomatic or consular mission operations, including bank transactions related to the operation of those missions, such as salary payments, expense reimbursement for employees, or payments of utilities for diplomatic or consular facilities.

Date Updated: January 10, 2025

Section 1(a)(i) of E.O. 14024 imposes sanctions with respect to any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, to operate or have operated in the technology sector or the defense and related materiel sector of the Russian Federation economy, or any other sector of the Russian Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State. As of January 10, 2025, persons may be sanctioned pursuant to E.O. 14024 for operating or having operated in the following sectors of the Russian Federation economy:

OFAC expects to promulgate regulations that define the terms (i) architecture sector of the Russian Federation economy, (ii) engineering sector of the Russian Federation economy, (iii) construction sector of the Russian Federation economy, (iv) manufacturing sector of the Russian Federation economy, (v) transportation sector of the Russian Federation economy; (vi) technology sector of the Russian Federation economy; (vii) defense and related materiel sector of the Russian Federation economy; (viii) aerospace sector of the Russian Federation economy; (ix) financial services sector of the Russian Federation economy; (x) electronics sector of the Russian Federation economy; (xi) marine sector of the Russian Federation economy, and (xii) energy sector of the Russian Federation economy consistent with the following:

Architecture sector of the Russian Federation economy: The term architecture sector of the Russian Federation economy includes activities such as advising; pre-designing; designing; preparing sketches, reports, studies, assessments, site plans, working drawings, specifications, cost estimates, as-built drawings, or other materials; contract administration; site selection; and inspections concerning architectural and related matters involving the Russian Federation.  Such activities may be related to the following types of projects, e.g.: residential, institutional, leisure, commercial, and industrial buildings and structures; recreational areas; transportation infrastructure; land subdivisions; urban planning; landscape architecture; and not necessarily relate to a new construction project. The term additionally includes any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the architecture sector of the Russian Federation economy.

Engineering sector of the Russian Federation economy: The term engineering sector of the Russian Federation economy includes activities such as advising; designing; recommending; consulting; constructing; installing, surveying; preparing studies, specifications, cost estimates, working drawings, process flow diagrams, arrangement drawings, or other materials; map making; planning; testing; analysis; and inspecting for engineering and related matters involving the Russian Federation.  Such activities may be undertaken during any phase of an engineering project of any type and may not necessarily relate to a new construction or development project.  The term additionally includes any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the engineering sector of the Russian Federation economy.

Construction sector of the Russian Federation economy: The term construction sector of the Russian Federation economy includes activities such as the production, procurement, devising, framing, design, testing, financing, distribution, or transport involving the Russian Federation, of goods, services, or technology to fabricate, shape, alter, maintain, or form any buildings or structures, including the on-site development, assembly, or construction of residential, commercial, or institutional buildings, or of transportation infrastructure, in the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the construction sector of the Russian Federation economy.

Manufacturing sector of the Russian Federation economy: The term manufacturing sector of the Russian Federation economy includes activities such as the creation, modification, repair, testing, or financing, of goods by manual labor or machinery involving the Russian Federation and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the manufacturing sector of the Russian Federation economy.  Note that persons conducting or facilitating transactions that are exempt or authorized by OFAC—such as those related to the provision of agricultural commodities, food, medicine, or medical devices, or related to civil nuclear energy—will not be subject to sanctions under E.O. 14024.

Transportation sector of the Russian Federation economy: The term transportation sector of the Russian Federation economy includes activities such as the production, manufacturing, testing, financing, distribution or transport to, from, or involving the Russian Federation of any mode of transport or any goods, services, or technology for the movement or conveyance of persons or property and the loading, unloading, or storage incidental to the movement of such persons or property; and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the transportation sector of the Russian Federation economy.

Technology sector of the Russian Federation economy: The term technology sector of the Russian Federation economy includes activities such as the production, procurement, research, development, design, engineering, testing, servicing, financing, distribution, use, or transport involving the Russian Federation, of software, equipment, electronics, items, tools, materials, or devices, and any components, parts, or accessories of the foregoing, related to the fields of computing, engineering, applied mathematics, or applied sciences involving the Russian Federation and any related activities, including the provision or receipt of goods or services involving the technology sector of the Russian Federation economy.

Defense and related materiel sector of the Russian Federation economy: The term defense and related materiel sector of the Russian Federation economy includes military, armed forces, or security forces of or within the Russian Federation; the use of arms or related materiel by military, armed forces, or security forces of or within the Russian Federation; any person designing, developing, manufacturing, supplying, financing, procuring, or distributing goods, services, or technology to, from, or involving military, armed forces, or security forces of or within the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology involving the defense and related materiel sector of the Russian Federation economy.  The term defense and related materiel sector of the Russian Federation economy also includes acquisition, possession, procurement, research, design, development, testing, evaluation, manufacture, maintenance, upgrade or refurbishment, shipping, supply, sale, transfer, or storage to, from, within, for, transiting, or on behalf of the Russian Federation of arms or related materiel of all types; enablers, aggregates, components, parts, as well as related documentation and instructions for any such arms or related materiel; or training for the use of included systems, provision of simulation equipment, documentation (including training manuals, maintenance orders, or technical bulletins), prototypes, software upgrades, and licensing and manufacturing agreements for such items.

Aerospace sector of the Russian Federation economy: The term aerospace sector of the Russian Federation economy includes activities such as the production, procurement, development, design, testing, servicing, financing, distribution, use, or transport involving the Russian Federation and its airspace, of aircraft or any other device used or intended to be used for flight or activities in the air or in space, missiles, unmanned aerial vehicles, space-based vehicles, satellites, high-altitude balloons, any other device that operates above the surface of the earth, and any items, components, parts, or accessories intended for the foregoing; airports or any other area of land or water used or intended to be used for a purpose related to the aerospace sector of the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology involving the aerospace sector of the Russian Federation economy.

Financial services sector of the Russian Federation economy: The term financial services sector of the Russian Federation economy includes economic or financial services in, involving the Russian Federation, including government-operated and private banks, depository institutions, credit card companies, investment banking services, foreign exchange services, money services businesses, payday lenders, mortgage companies, securities exchanges, securities dealers, asset managers, insurance companies, other financial institutions, and any persons in the business of accepting deposits, transferring funds, facilitating investment, making, granting, transferring, holding, or brokering loans or credits, or purchasing or selling foreign exchange, securities, commodity futures or options, or procuring purchasers and sellers thereof, as principal or agent; and any related activities, including the provision or receipt of goods, services, or technology involving the financial services sector of the Russian Federation economy.

Electronics sector of the Russian Federation economy:  The term electronics sector of the Russian Federation economy includes activities such as the production, procurement, development, design, testing, servicing, financing, distribution, use, or transport to, from, or involving the Russian Federation, of computers, computer peripherals, semiconductors, electronic capacitors or resistors, coils, circuit boards, cryptographic software and hardware, or devices that control, direct, or utilize an electric current, and any items, components, parts, or accessories of the foregoing; and any related activities, in, or involving the Russian Federation, including the provision or receipt of goods, services, or technology involving the electronics sector of the Russian Federation economy.

Marine Sector of the Russian Federation economy: The term marine sector of the Russian Federation economy includes activities such as the production, procurement, development, design, testing, servicing, financing, distribution, use, or transport, to, from, or involving the Russian Federation or its marine waterways or oceanic exclusive economic zone, of vessels, or any device used or intended to be used in or otherwise relating to the sea or any navigable body of water, and any items, components, parts, or accessories of the foregoing; any activity relating to the sea or any body of navigable water; ports or any area of land or water used or intended to be used for any purpose related to the marine sector of the Russian Federation, including shipping; and any related activities, including the provision or receipt of goods, services, or technology involving the marine sector of the Russian Federation economy. The term includes the financing, sale, supply, or transfer of vessels to or from, directly or indirectly, the Russian Federation or any Russian Federation person.

Energy sector of the Russian Federation economy: The term energy sector of the Russian Federation economy includes activities such as the procurement, exploration, extraction, drilling, mining, harvesting, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, manufacturing, testing, financing, distribution, purchase or transport to, from, or involving the Russian Federation, of petroleum, including crude oil, lease condensates, unfinished oils, natural gas, liquefied natural gas, natural gas liquids, or petroleum products, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels; the development, production, testing, generation, transmission, financing, or exchange of power, through any means, including nuclear, electrical, thermal, and renewable, to, from,  or involving the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the energy sector of the Russian Federation economy.

Date Updated: January 10, 2025

Russia-related GL 1B authorizes U.S. persons to engage in certain transactions and activities involving the Federal State Budgetary Institution Marine Rescue Service (MRS) that are otherwise prohibited by Executive Order (E.O.) 14039 of August 20, 2021, "Blocking Property with Respect to Certain Russian Energy Export Pipelines," the Protecting Europe's Energy Security Act of 2019, 22 U.S.C. 9526 note, as amended (PEESA), or E.O. 14024.

An earlier version of this GL was issued on May 21, 2021 (GL 1) and amended on August 20, 2021 (GL 1A) concurrent with the promulgation of E.O. 14039. On December 18, 2024, GL 1A was amended and re-issued following the designation of MRS under E.O. 14024. Russia-related GL 1B replaces and supersedes GL 1A effective December 18, 2024.

GL 1B authorizes U.S. persons to engage in transactions and activities involving MRS, or any entity in which MRS owns, directly or indirectly, a 50 percent or greater interest, that are not related to the construction of the Nord Stream 2 pipeline project, the TurkStream pipeline project, or any project that is a successor to either such project. GL 1B does not, however, authorize any transactions or activities with any vessels identified on the Office of Foreign Assets Control’s List of Specially Designated Nationals and Blocked Persons (SDN List) as blocked property of MRS, including vessels identified as blocked property of any entity in which MRS owns, directly or indirectly, a 50 percent or greater interest.

Date Updated: December 18, 2024

Yes. OFAC has multiple e-mail subscription services available. Please visit the following link to sign up for these services:

https://service.govdelivery.com/service/multi_subscribe.html?code=USTREAS

Date Updated: November 22, 2024

Yes. On June 12, 2024, OFAC designated the National Settlement Depository (NSD), along with the Moscow Exchange (MOEX) and the National Clearing Center (NCC) pursuant to Executive Order (E.O.) 14024 for operating or having operated in the financial services sector of the Russian Federation economy. As noted in the accompanying press release, Russia has reoriented the architecture of its financial system to facilitate investment into its defense industry and acquisition of goods needed to further its aggression against Ukraine.

Alongside this designation, OFAC issued, and subsequently extended, two general licenses (GLs) to allow for the wind down of certain transactions involving NSD, MOEX, and NCC, and the divestment of securities held at NSD, among other authorized activities. Following the expiration of Russia-related GLs 99A and 100A, any securities in the possession or control of U.S. persons that are held at NSD should be treated as blocked, and dividends or other income received via NSD should be treated as blocked.

A version of this FAQ released on October 10, 2024 provided guidance that the Russian Federation has attempted to take action to evade or avoid OFAC sanctions on NSD via Presidential Decree 840 by requiring the transfer of certain securities to local Russian registrars. This FAQ cautioned that such transfers may be considered null and void pursuant to OFAC's regulations (see 31 CFR § 587.202), and that OFAC understands that these transactions may involve other blocked persons, including certain local Russian registrars. This FAQ also noted that the general licenses did not authorize transactions involving any blocked person other than those identified in the authorizations, and that any transfer made in violation of OFAC sanctions is null and void. As such, OFAC cautioned that U.S. persons should continue to treat these securities as blocked.

On November 21, 2024, OFAC designated more than 40 local Russian registrars pursuant to E.O. 14024. As such, any securities in the possession or control of U.S. persons that are held at these registrars should be treated as blocked, and dividends or any income received via these registrars should be treated as blocked. Any U.S. persons who have already filed initial blocking reports on such securities do not need to file amended reports solely due to a change in local Russian registrar and can use their Annual Reports of Blocked Property to reflect any updated information if necessary.

Date Updated: November 21, 2024

OFAC issued Russia-related General License (GL) 53A to authorize U.S. persons to engage in all transactions ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation ("Russian missions"), where the transactions are prohibited by Executive Order (E.O.) 14024 and involve Gazprombank, or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest, or are prohibited by Directive 4 under E.O. 14024, "Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation." This authorization applies to transactions related to Russian missions located in or outside the United States. For example, GL 53A authorizes the payment of salaries to employees of Russian missions that may otherwise be prohibited by Directive 4, such as a payment originated by the Ministry of Finance of the Russian Federation from a non-blocked Russian bank. GL 53A also authorizes the payment of salaries to employees of Russian missions that may otherwise be prohibited due to the involvement of Gazprombank. Non-U.S. persons may engage in transactions that are authorized for U.S. persons under this GL without risk of sanctions under E.O. 14024.

Importantly, GL 53A does not authorize any transactions involving blocked persons other than Gazprombank, including blocked Russian financial institutions, nor does it authorize debits to the accounts on the books of U.S. financial institutions of entities subject to Directive 4.

Date Updated: November 21, 2024

Yes, provided that the provision of global travel insurance and travel assistance relate to travel that is exempt or authorized. The authority granted to the President by the International Emergency Economic Powers Act (IEEPA) does not include the authority to regulate or prohibit, directly or indirectly, transactions ordinarily incident to travel to or from any country. See 50 U.S.C. §1702 (b)(4). OFAC sanctions programs issued pursuant to IEEPA generally do not prohibit transactions ordinarily incident to travel to or from any country, including the issuance and provision of travel-related insurance coverage related to exempt travel.

Although the Trading with the Enemy Act (TWEA) does not exempt travel from the President’s authority, the TWEA-based Cuban Assets Control Regulations (CACR) authorize travel in limited circumstances. Travel related services, including travel insurance coverage, may only be provided in Cuba pursuant to a valid general or specific OFAC license. For example, if the traveler is a U.S. person traveling to Cuba pursuant to a valid OFAC authorization, a U.S. insurer may issue travel insurance to the traveler without obtaining a separate authorization.

Similarly, U.S. persons may issue or provide coverage for global health, life, or travel insurance policies for individuals ordinarily resident in a country outside of Cuba who travel to or within Cuba, pursuant to the general license at 31 C.F.R. § 515.580 of the CACR, as well as service such policies and pay claims arising from events that occurred while the individual was traveling in, or to or from, Cuba. (For more information, see FAQ 774.)

Additionally, insurers should check OFAC's List of Specially Designated Nationals and Blocked Persons List (SDN List) and other sanctions lists to ensure that no prohibited services are rendered to persons or entities on those lists.

Date Updated: November 13, 2024

OFAC recognizes that U.S. insurers and reinsurers often compete in international markets where non-U.S. insurers are willing and able to issue global insurance policies without an exclusion that applies to U.S. sanctions, or where such clauses may be prohibited under local law. In cases where an exclusionary clause, as described in FAQ 102, is not commercially feasible, but the policy would involve the provision of coverage to a sanctioned person or jurisdiction, or prohibited activity, the insurer should apply to OFAC for a specific license prior to issuing the global insurance policy. In determining whether to issue a license, OFAC will review the facts and circumstances of each global insurance policy, including the market position of the applicant and the relevant risk frequency and risk severity, to assure that issuance of the policy will not undermine U.S. foreign policy goals. A separate license would typically be required for the insurer to pay claims that would be prohibited under U.S. sanctions arising under any authorized global insurance policy. For guidance on how to request and apply for a specific license, please see 31 CFR § 501.801 and the OFAC License Application page on OFAC's website.

Date Updated: November 13, 2024

The best and most reliable approach for issuing policies with global risk coverage without violating U.S. sanctions law is to include a clause ensuring there is no coverage for risks that violate U.S. sanctions law. The exact wording of such clauses may vary depending on the type of policy (e.g., open marine cargo policies versus personal accident policies), but the legal effect of the clause should prevent the extension of a prohibited service (e.g., insurance coverage or indemnification) to sanctioned persons or jurisdictions, or for prohibited activities. Insurers should also ensure such clauses do not create future economic benefit for a sanctioned person or jurisdiction by allowing for indemnification if or when relevant prohibitions no longer apply; there should be no coverage at the time of loss if, at that time, such coverage would have violated U.S. sanctions law.

In the event of a loss occurring, and there is a question of whether a counterparty to the loss (e.g., the insured) was in violation of U.S. sanctions, the insurer should contact OFAC directly.

Date Updated: November 13, 2024

The insurer may instruct the policyholder that in accordance with applicable U.S. laws and regulations administered by OFAC, the insurer must place any subsequent premium payments into a blocked account.

For funds, such as unearned premium payments, that are blocked in addition to the policy, an insurer may notify the policyholder that it has blocked funds in accordance with OFAC's regulations. The insurer may identify to the policyholder the corresponding sanctions program pursuant to which the insured took action.

Any individual or entity whose funds or other property have been blocked due to OFAC-administered sanctions may apply for the release of the funds or other property via the License Application page on OFAC's website.

For additional questions about OFAC sanctions, you are encouraged to have the policyholder contact OFAC directly.

Date Updated: November 13, 2024

Yes. The insurer may notify the policyholder that the policy is blocked without obtaining a specific license from OFAC.

Date Updated: November 13, 2024

OFAC may impose civil penalties for sanctions violations based on strict liability, meaning that a person subject to U.S. jurisdiction may be held civilly liable even if such person did not have knowledge that it was engaging in a transaction that was prohibited under sanctions laws and regulations administered by OFAC.

OFAC recommends insurers use a risk-based approach to sanctions compliance consistent with OFAC’s Framework for Compliance Commitments.  Sanctions compliance programs, including screening frequency, will vary depending on the size and nature of an insurer’s business (including the particular risk factors of its products and customer base) and its relevant regulator.  Routine screening of all issued policies, policyholders, beneficiaries, and other relevant counterparties improves an insurer’s ability to comply with applicable OFAC regulatory requirements.  

In addition to screening all relevant policyholders, beneficiaries, and counterparties to an insurance policy upon issuance (as described in FAQ 62), insurers should also consider screening against OFAC sanctions at policy renewal, policy amendment (including, but not limited to, the addition of insured parties or beneficiaries to the policy), claim submission, claim payment, updates by OFAC to its sanctions or sanctions lists, and at any other time when an insurer may be exposed to sanctions risk. OFAC's sanctions programs and lists are updated frequently.  Screening only at the point of policy issuance may expose insurers to sanctions risk, for example, providing financial benefit to subsequently blocked persons.  

Date Updated: November 13, 2024

If an insurer has knowledge that a person covered under a group policy, for example a worker's compensation policy, is blocked pursuant to OFAC sanctions, the insurer’s coverage of that person pursuant to the worker's compensation policy is blocked. If a claim is made under the blocked portion of the policy, the claim cannot be paid without authorization from OFAC. Any premium payments made by or on behalf of the blocked person should be blocked and placed in a blocked interest-bearing account at a U.S. financial institution.

Alternatively, under some group policies, for example, a group travel policy issued to a company for their employees, an insurer may not know the names of those covered until a claim is filed. In this scenario, once a claim is filed by a blocked person, the insurer would then have reason to know of their requirement to block that individual’s coverage pursuant to the policy and any other property of that person, such as unearned premium payments. Accordingly, the insurer would be required to block that individual’s coverage and place any payments made by or on behalf of the blocked person in a blocked interest-bearing account at a U.S. financial institution.

If a person covered under a group policy is on one of OFAC's other sanctions lists or is located in a jurisdiction where OFAC has imposed broad sanctions prohibitions, a different set of restrictions may apply. If a claim is filed by an individual on one of OFAC's other sanctions lists, please see the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC's website for program-specific information or contact OFAC for additional guidance.

Date Updated: November 13, 2024

If an existing policyholder or a named beneficiary is blocked by OFAC and the provision of insurance services is not authorized or exempt, then the insurer is required to block the policy or relevant portion of the policy (e.g., the individual's policy under a group health insurance plan), report such blocking to OFAC within 10 business days from the date the policy becomes blocked, place any future premium payments into a blocked interest-bearing account at a U.S. financial institution, and, if applicable, seek an OFAC specific license to make any payments under the policy. For guidance on how to request and apply for a specific license, please see 31 CFR § 501.801 and the License Application page on OFAC's website.

In the case of sanctions that prohibit the provision of services to a particular jurisdiction, in most cases insurers should cease providing coverage to the relevant policyholder or named beneficiary located within the jurisdiction or with respect to the particular jurisdiction unless authorized by OFAC or otherwise exempt. (For more information on travel-related insurance coverage, see FAQ 104.)

The insurance company may contact OFAC with specific questions related to the policy.

Date Updated: November 13, 2024

Insurance industry participants, including underwriters, brokers, and agents, are responsible for compliance with OFAC sanctions throughout the lifecycle of their involvement with an insurance policy or other product or service.

If a U.S. insurer receives an application for a policy from a person whose property and interests in property are blocked, such as a person on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), OFAC sanctions prohibit the insurer from issuing the policy, unless authorized or exempt, because doing so would provide a service (i.e., coverage) to the blocked person. If the blocked person sends a deposit to the insurer along with the application, the deposit must be blocked and reported to OFAC within 10 business days, unless authorized or exempt. If an insurer receives an application from a party on one of OFAC's other sanctions lists, please review the relevant prohibitions carefully before taking any action. For information on specific prohibitions, authorizations, or exemptions under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC's website.

Date Updated: November 13, 2024

Yes. OFAC's regulations under the Trading with the Enemy Act (TWEA) and the International Emergency Economic Powers Act (IEEPA) are based on presidential declarations of national emergency and preempt state insurance regulations.

For more information on who must comply with OFAC sanctions, see FAQ 11.

Date Updated: November 13, 2024

GL 25G authorizes certain transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR). In addition, GL 25G authorizes certain transactions from the United States or by U.S. persons, wherever located, to the Russian Federation that are incident to the exchange of communications over the internet and that are prohibited by the RuHSR. With respect to software, hardware, and technology, GL 25G authorizes the exportation or reexportation, sale, or supply from the United States or by U.S. persons, wherever located, to the Russian Federation of software, hardware, or technology incident to the exchange of communications over the internet that is authorized for export to Russia by the Department of Commerce if it is subject to the Export Administration Regulations, 15 CFR parts 730-774 (EAR), or that would be eligible for a license exception or otherwise authorized for export to Russia by the Department of Commerce if it were subject to the EAR. However, GL 25G explicitly excludes from the authorization any transactions that are prohibited by the RuHSR involving Joint Stock Company Channel One Russia, Television Station Russia-1, Joint Stock Company NTV Broadcasting Company, Limited Liability Company Algoritm, New Eastern Outlook, Oriental Review, Garantex Europe OU, Autonomous Non-Profit Organization Dialog, Autonomous Non-Profit Organization Dialog Regions, Federal State Unitary Enterprise International Information Agency Rossiya Segodnya, Autonomous Non Profit Organization TV Novosti, XH Smart Tech China Co Ltd, or CJSC Perspective Technologies Agency, which are designated pursuant to Executive Order 14024.

For further information on relevant authorizations, exemptions, and public guidance, please review OFAC's Fact Sheet, "Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine."

Date Updated: October 30, 2024

On May 8, 2022, the Director of OFAC, in consultation with the Department of State, issued a determination pursuant to Executive Order (E.O.) 14071, "Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services," prohibiting the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of certain accounting, trust and corporate formation, and management consulting services to any person located in the Russian Federation. This determination takes effect June 07, 2022. For more information, please see FAQ 1034.

On May 08, 2022, the Director of OFAC, in consultation with the Department of State, also issued a sectoral determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on individuals and entities that operate or have operated in the accounting, trust and corporate formation services, or management consulting sectors of the Russian Federation economy. This determination takes effect on May 08, 2022. For further information, please see FAQ 1034.

On June 12, 2024, the Department of the Treasury issued a determination that restricts the provision of certain IT and software-related services to Russia, including prohibiting the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, to any person located in the Russian Federation of IT support services and cloud-based services for the following categories of software: enterprise management software and design and manufacturing software (collectively, "Covered Software"). These prohibitions took effect on September 12, 2024. See FAQs 1184 – 1188 for additional information.

Date Updated: September 12, 2024

The Diamonds Determination prohibits the importation and entry into the United States of two categories of diamonds, effective on the dates indicated below.

Effective March 01, 2024, the Diamonds Determination prohibits the importation of non-industrial diamonds that were mined, extracted, produced, or manufactured wholly or in part in the Russian Federation with a weight of 1.0 carat or greater, even if such diamonds have been substantially transformed into other products outside of the Russian Federation.

Effective September 01, 2024, the Diamonds Determination prohibits the importation of Russian non-industrial diamonds with a weight of 0.5 carats or greater, even if such diamonds have been substantially transformed into other products outside of the Russian Federation.

For example, a non-industrial diamond that is mined in Russia but then undergoes manufacturing operations such as being cut, faceted, or polished in a third country, is prohibited from importation and entry into the United States, if at the time of importation, it is 1.0 carat or greater as of March 01, 2024 or 0.5 carats or greater as of September 01, 2024.

See FAQ 1027 for the definition of non-industrial diamonds. See FAQ 1166 for information on the prohibition related to diamond jewelry and unsorted diamonds.

Pursuant to General License (GL) 104, U.S. persons are authorized to import into the United States non-industrial diamonds, substantially transformed into other products outside of the Russian Federation, with a weight of 1.0 carat or greater, if those diamonds were physically located outside of the Russian Federation before, and not exported or reexported from the Russian Federation since, March 01, 2024. GL 104 also authorizes the importation into the United States of non-industrial diamonds, substantially transformed into other products outside of the Russian Federation, with a weight of 0.5 carats or greater if those diamonds were physically located outside of the Russian Federation before, and not exported or reexported from the Russian Federation since, September 01, 2024. See FAQ 1189 for additional information.

Date Updated: August 23, 2024.

No. OFAC does not issue non-inclusion certificates to show an entity or individual is not listed on one of OFAC’s sanctions lists, nor does OFAC publish a “safe list.” For questions regarding whether a specific entity or individual may be a positive match to an entry on one of OFAC’s sanctions lists, please see FAQ 5 or the OFAC Basics Videos Series.

Date Updated: August 21, 2024.

If you have questions about the authenticity of an OFAC-issued document that is not publicly posted on OFAC’s website, you may contact OFAC and reference the specific case ID or FAC number that is included on the document.

• For specific licenses, please visit OFAC’s Licensing Portal and select the "Check Application Status" feature.
• For a removal letter regarding OFAC’s List of Specially Designated Nationals and Blocked Persons or any other sanctions list maintained by OFAC, please email OFAC.Reconsideration@treasury.gov. Alternatively, you may check OFAC’s Sanctions List Search tool to search OFAC’s current sanctions lists.
• For any another OFAC-issued document, please contact OFAC as described here.

Date Updated: August 21, 2024.

A package may be blocked or rejected for multiple reasons. U.S. persons, including shipping companies, are required to "block" packages in which a person blocked by OFAC-administered sanctions has an interest. When a package is required to be "blocked" due to sanctions, the shipper must retain the package rather than return it to the sender. In other circumstances, sanctions may not require that the package be blocked, but a shipping company may have to return your package, or "reject" it. For example, if the package was destined for a location under a U.S. trade embargo and was not otherwise eligible to be shipped in accordance with an existing exemption or OFAC authorization, the shipping company may reject and return your package.

If your package was blocked due to OFAC sanctions, you may request authorization from OFAC for the blocked package to be released by submitting a License Application that includes a detailed description of the package’s contents and an explanation of the package’s air waybill or Customs Declaration and Dispatch form.

Please see the Sanctions Programs and Country Information page on OFAC’s website for more information on the restrictions on shipments to sanctioned jurisdictions.

Date Updated: August 21, 2024.

OFAC publishes lists of individuals and entities that are subject to OFAC-administered sanctions. One such list is known as the List of Specially Designated Nationals and Blocked Persons List, or "SDN List," which is available on OFAC’s website. Property and interests in property of the individuals and entities on the SDN List, that is within the United States or within the possession or control of U.S. persons are blocked. Additionally, U.S. persons are generally prohibited from dealing with the individuals and entities on the SDN List.

It is important to note that some OFAC sanctions block categories of persons even if those persons do not appear on the SDN List, including most Cuban nationals, blocked foreign governments, or persons blocked pursuant to OFAC’s "50 Percent Rule" (i.e., any entity owned individually or in the aggregate, directly or indirectly, 50 percent or more by one or more blocked persons). The property and interests in property of such an entity are blocked regardless of whether the entity itself is listed on the SDN List.

In addition, OFAC maintains other sanctions lists of persons that are subject to non-blocking sanctions.  These lists are also available on OFAC’s website. For information on specific prohibitions under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC’s website.

Date Updated: August 21, 2024.

Violations of OFAC-administered sanctions programs may result in civil and, in some cases, criminal penalties. Penalties for violations can be substantial. Civil penalties vary by sanctions program, and the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended by the Federal Civil Penalty Inflation Adjustment Act Improvements Act of 2015, requires OFAC to adjust civil monetary penalty amounts annually. For current penalty amounts, see Appendix A to 31 CFR part 501—Economic Sanctions Enforcement Guidelines. For a list of select OFAC enforcement actions, organized by year, please see the Civil Penalties and Enforcement Information page on OFAC’s website.

Date Updated: August 21, 2024.

All U.S. persons must comply with OFAC sanctions, including all U.S. citizens and permanent residents regardless of where they are located, all individuals and entities within the United States, and all U.S. incorporated entities and their foreign branches. Terms such as "U.S. person" and "person subject to U.S. jurisdiction" are defined in the implementing regulations for a particular sanctions program in 31 CFR chapter V. (See e.g., 31 CFR § 560.314 (Iranian Transactions and Sanctions Regulations (ITSR)); 31 CFR § 598.318 (Foreign Narcotics Kingpin Sanctions Regulations). In the case of certain programs, foreign subsidiaries owned or controlled by U.S. persons also must comply. (See e.g., 31 CFR § 560.215 (ITSR); 31 CFR § 510.214 (North Korea Sanctions Regulations)). Non-U.S. persons are also subject to certain sanctions prohibitions. For example, non-U.S. persons are prohibited from causing or conspiring to cause U.S. persons to violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. Certain programs also require foreign persons reexporting certain goods, technology, or services from the United States to comply with U.S. sanctions, even if no U.S. persons are involved in the reexport.

Date Updated: August 21, 2024.

"Blocking" refers to freezing assets or other property. Blocking immediately imposes an across-the-board prohibition against transfers or dealings of any kind with regard to the property.

OFAC authorities may require U.S. persons to block all property and interests in property of certain persons, known as "blocked persons." When this is the case, any property and interests in property of a blocked person that are within the United States or within the possession or control of a U.S. person must be blocked (i.e., "frozen")—not seized—and may not be transferred, withdrawn, or otherwise dealt in. Title to the blocked property remains with the blocked person, but the exercise of powers and privileges normally associated with ownership is prohibited without authorization from OFAC.

In addition, parties must report blocked property to OFAC within 10 business days of the property becoming blocked. Blocked persons include persons that appear on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), foreign governments subject to blocking, and persons blocked pursuant to OFAC’s “50 Percent Rule.” For further information, see FAQ 401 and OFAC guidance on the "50 Percent Rule."

The term "property," as defined in various OFAC regulations, includes financial property (e.g., money, checks, savings accounts, stocks, bonds, debt, or any other financial instruments), real, tangible, and intangible assets (e.g., goods, merchandise, ships, land contracts, and real estate), and any other property or interests therein present, future, or contingent. For information on how OFAC defines property in a particular sanctions program, please see the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC’s website.

Date Updated: August 21, 2024.

OFAC issues general licenses to authorize certain transactions that would otherwise be prohibited pursuant to a particular sanctions program. These general licenses are self-executing, meaning they allow persons to engage in certain transactions involving the United States or U.S. persons without needing to apply for a specific license, provided the transactions meet certain terms and conditions as described in the general license. In addition, some categories of activities, such as personal communications and transactions ordinarily incident to travel, may be exempt from sanctions in certain programs. Subject to sanctions program-specific considerations, non-U.S. persons do not generally risk being sanctioned for engaging in or facilitating transactions for which a U.S. person would not require a specific license.

If you seek to engage in a prohibited transaction involving a U.S. person or blocked property and there is no applicable general license or exemption, you may apply for a specific license from OFAC by submitting a license application. OFAC may grant, on a case-by-case basis, a specific license to authorize a person to engage in a transaction, or series of transactions, that otherwise would be prohibited by sanctions. For guidance on how to request and apply for a specific license, please see 31 CFR § 501.801 and the License Application page on OFAC’s website.

Date Updated: August 21, 2024.

References to relevant statutes, executive orders, regulations, guidance, general licenses, and sanctions actions for each sanctions program may be found in the Sanctions Programs and Country Information page on OFAC’s website. The OFAC Legal Library page on OFAC’s website also contains links to the relevant legal authorities, including statutes, executive orders, and the Code of Federal Regulations, where specific OFAC sanctions regulations can be found.

Date Updated: August 21, 2024.

Yes. There may be exceptions to sanctions prohibitions. Exceptions may take the form of authorizations, such as general licenses and specific licenses, or exemptions.

OFAC issues general licenses in most of its sanctions programs to authorize certain transactions that would otherwise be prohibited, such as transactions related to humanitarian activities or official business of the U.S. government. General licenses are self-executing, meaning they allow persons to engage in certain transactions involving the United States or U.S. persons without needing to apply for a specific license provided the transactions meet certain terms and conditions as described in the general license.

OFAC may also issue specific licenses on a case-by-case basis. In contrast to general licenses, which authorize certain transactions for all persons who meet the conditions described in the license, specific licenses only authorize the licensee(s) to engage in certain transactions that would otherwise be prohibited. For guidance on how to request and apply for a specific license, please see 31 CFR § 501.801 and the License Application page on OFAC’s website.

Exceptions may also take the form of exemptions, meaning certain types of transactions are exempt from sanctions and therefore not prohibited. For example, in certain sanctions programs transactions involving personal communications, humanitarian donations, information or informational materials, and travel are exempt from relevant prohibitions.

Most OFAC sanctions programs have certain exceptions, but exceptions may vary in type and scope across different sanctions programs. For information on the authorizations or exemptions under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC’s website.

Date Updated: August 21, 2024.

Each OFAC sanctions program is based on different foreign policy and national security goals, so the prohibitions imposed may vary between programs. Many sanctions programs require blocking the property and interests in property of specific individuals and entities and prohibit dealing in such blocked property. (For more information, see FAQ 9.) OFAC sanctions prohibitions may also take many other forms that do not require blocking but prohibit U.S. persons from engaging in certain trade or financial transactions and other dealings unless authorized by OFAC or exempted by statute. Non-U.S. persons are also subject to certain OFAC prohibitions.  For example, non-U.S. persons are prohibited from causing or conspiring to cause U.S. persons to violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. For information on specific prohibitions, authorizations, or exemptions under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC’s website.

Date Updated: August 21, 2024.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions against targeted foreign jurisdictions and regimes, as well as individuals and entities engaging in harmful activity, such as terrorists, international narcotics traffickers, weapons of mass destruction proliferators, and other malign actors, in response to threats to the national security, foreign policy, or economy of the United States. OFAC sanctions take various forms, from blocking the property of specific individuals and entities to broadly prohibiting transactions involving an entire country or geographic region, such as through a trade embargo or prohibitions related to particular sectors of a country’s economy.

Read more about OFAC’s history on the About OFAC page on OFAC’s website.

Date Updated: August 21, 2024.

On May 17, 2024, OFAC amended 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) to incorporate the provisions of General License (GL) D-2 into 31 CFR § 560.540, with certain additional amendments. Section 560.540 supersedes GL D-2, which OFAC issued on September 23, 2022, to further support the provision of communication tools to ordinary Iranians and assist in their efforts to resist repressive internet censorship and surveillance tools deployed by the Iranian government.  In addition to incorporating GL D-2 into the ITSR, the amended 31 CFR § 560.540 includes several key changes:

• The list of services, software, and hardware incident to communications authorized for exportation, reexportation, or provision to Iran previously found in the Annex to GL D-2 is now found in the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications.
• Effective June 17, 2024 OFAC is amending the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications to exclude laptops, tablets, and personal computing devices with an "Adjusted Peak Performance" ("APP") exceeding 1 Weighted TeraFLOP (WT).
• The authorization previously found at paragraph (a)(5) of GL D-2 and now incorporated into 31 CFR § 560.540(a)(5) is revised to authorize transactions for the importation of hardware or software into third countries, in addition to the United States, provided that the items were previously exported to Iran pursuant to an authorization issued pursuant to the ITSR.
• OFAC has added a new 31 CFR § 560.540(a)(7) to authorize the exportation or reexportation of certain services conducted outside Iran to install, repair, or replace hardware or software authorized for exportation, reexportation, or provision to Iran by paragraphs (a)(2) or (3). The new 31 CFR § 560.540(a)(7) authorizes such services only when the service provider is located outside Iran and does not authorize the service provider to engage in such services while in Iran.
• Section 560.540(b)(3), which incorporates paragraph (b) of GL D-2, is also being revised to clarify the restrictions related to provision of web-hosting services or of domain name registration services in Iran authorized by 31 CFR § 560.540(a) by specifically excluding from authorization the exportation or reexportation of web-hosting services for websites of commercial entities located in Iran or of domain name registration services for or on behalf of the Government of Iran or another person whose property and interests in property are blocked pursuant to Section 560.211 of the ITSR.
• Section 560.540(d) has been added to set forth the case-by-case licensing policy previously set forth in paragraph (d) of GL D-2, for additional activities that support internet freedom in Iran, such as development and hosting of anti-surveillance software by Iranian developers. Such services would also include, for example, the development and hosting of anti-censoring software by Iranian software developers and the exportation of certain software development tools to Iranians seeking to create their own anti-surveillance or anti-censorship apps and upload them to mobile app sites.

Date Updated: May 16, 2024

Yes, persons seeking to export software, services, or hardware to Iran or conduct other activities in support of internet freedom in Iran that are not exempt transactions or authorized by the general license in 31 CFR § 560.540 or other authorizations are encouraged to submit a specific license application to through the OFAC License Application Page. 

Date Updated: May 16, 2024

A cloud-based service or software provider whose non-Iranian customers provide services or software to persons in Iran via the cloud may rely upon the authorization in 31 CFR § 560.540 to provide access to Iran, provided that such provider conducts due diligence based on information available to it in the ordinary course of business to confirm that the non-Iranian customer: (1) is not a person whose property and interests in property are blocked, except as authorized under paragraph (a)(6) of 31 CFR § 560.540; and (2) provides software and services that fall within one of the categories described in FAQ 1087, including activity authorized or exempt under the ITSR.

In instances where cloud-based services or software are used to support the exportation of services or software to Iran authorized under 31 CFR § 560.540, OFAC does not generally expect a cloud-based service or software provider to evaluate the ultimate end use or end user of the authorized software or services, provided the cloud-based provider conducts due diligence based on information available to it in the ordinary course of business.  For example, if a cloud-based service or software provider supports non-Iranian customers providing access in Iran to news websites or Virtual Private Networks (VPNs) that fall within one of the categories described in FAQ 1087, the cloud-based service or software provider need not evaluate whether the provision of access via the cloud involving Iranian end users is related to communication.  By contrast, if a U.S. cloud-based service or software provider supports non-Iranian customers providing certain enterprise management software to Iran, such as payroll management software, the cloud-based service or software provider would be expected to evaluate whether its support of the software is a prohibited export of software or services to Iran because payroll management software is not generally considered a qualifying software incident to communications.

Please note that 31 CFR § 560.540 does not authorize the importation into the United States of Iranian-origin software or the dealing in such software, including the hosting of Iranian-origin software on a mobile application store.  Persons seeking to engage in such activity may submit applications for specific licenses to OFAC that describe the nature of the software and the Iranian developers involved.

Date Updated: May 16, 2024

Yes.  Section 560.540(a)(1) of the ITSR authorizes the exportation to Iran of fee-based or no-cost cloud-based services incident to the exchange of communications over the internet.  In addition, 31 CFR § 560.540(a)(2) authorizes the exportation to Iran of cloud-based software that is incident to, or enables services incident to, communications over the Internet.  Software exported under 31 CFR § 560.540(a)(2) either: (i) must be designated as EAR99 under the Export Administration Regulations, 15 CFR parts 730 through 774 (EAR), excluded from the EAR because it is described under 15 CFR § 734,3(b)(3), or classified under Export Control Classification Number (ECCN) 5D992.c; or (ii) if the software is not subject to the EAR because it is of foreign origin, must be the type of software that would be designated EAR99 or classified under ECCN 5D992.c if it were subject to the EAR.
For purposes of 31 CFR § 560.540, cloud-based services and software are determined to be incident to the exchange of communications over the Internet when they are used to support transactions authorized or exempt under the ITSR, including the following categories of activities: 

• instant messaging, chat, email, social networking, sharing of photos and movies, web browsing, blogging, social media platforms, collaboration platforms, video conferencing, e-gaming platforms, e-learning platforms, automated translation, web maps, and user authentication services; 
• the export, reexport, or provision of software and services listed in the categories (6) through (11) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications, including anti-virus and anti-malware software, anti-tracking software, mobile operating systems and related software, anti-censorship tools and related software; Virtual Private Network (VPN) client software and related software; and provisioning and verification software for Secure Sockets Layers (SSL) certificates and related software, provided that the software meets the relevant conditions of 31 CFR § 560.540, including applicable export control classification-related criteria;
• transactions that are exempt from the prohibitions of the ITSR, including news outlets and media websites covered by the exemption for information or informational materials in 31 CFR § 560.210(c) of the ITSR; and
• other transactions authorized under the ITSR, such as transactions necessary and ordinarily incident to publishing authorized pursuant to 31 CFR § 560.538, transactions for the conduct of the official business of certain international organizations pursuant to 31 CFR § 560.539, the sale and exportation of agricultural commodities, medicine, medical devices, and certain software and services pursuant to 31 CFR § 560.530, and transactions authorized pursuant to any general or specific licenses issued under the ITSR. 

Please note that 31 CFR § 560.540(a)(1) does not authorize the exportation of cloud-based services or software to the Government of Iran, except as specified in 31 CFR § 560.540(a)(6). 

Date Updated: May 16, 2024

General licenses issued under the Iranian Transactions and Sanctions Regulations (ITSR) authorize certain U.S. academic institutions and other U.S. persons to provide certain services and software to Iranian students.  These general licenses include:

• General License G (GL G) authorizes accredited graduate and undergraduate degree-granting U.S. academic institutions, including their contractors, to export services to students located in Iran, or located outside of Iran but who are ordinarily resident in Iran (“Iranian students”), to sign up for and participate in certain undergraduate level online courses, notably:  (i) courses in the humanities, social sciences, law, or business that are the equivalent of courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business; and (ii) introductory undergraduate level science, technology, engineering, or mathematics courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business.  In addition, under 31 CFR § 560.405, certain transactions ordinarily incident to a licensed transaction are also authorized.  OFAC interprets 31 CFR § 560.405 to authorize certain transactions ordinarily incident to courses authorized by GL G, including the giving of assignments and testing and grading of Iranian students. 
• Section 560.540 of the ITSR authorizes the exportation to Iran of certain services and software incident to the exchange of communications over the internet, such as instant messaging, chat and email, social networking, sharing of photos and movies, web browsing, blogging, social media platforms, collaboration platforms, video conferencing, e-gaming platforms, e-learning platforms, automated translation, web maps, and user authentication services, as well as certain cloud-based services.  OFAC interprets these authorizations to cover video conferencing software and related services, as well as educational technology software and related services, that allow students to view courses and course materials, complete tests and assignments, receive grades, participate in discussions, and other, similar course-related online activity, provided that the software meets the additional criteria of the applicable authorization.  For more guidance on 31 CFR § 560.540 of the ITSR, please see FAQs 338–348, 434–443, 1087–1089, and 1110.

To export services to Iranian students that fall outside of these authorizations, U.S. persons may apply for a specific license through the OFAC License Application Page. 

Please note that the general licenses summarized above do not authorize the exportation of goods (including software), services, or technology to the Government of Iran, except as authorized under 31 CFR § 560.540(a)(6), or to persons blocked under any authority administered by OFAC, including OFAC’s counterterrorism or counterproliferation authorities. 

Date Updated: May 16, 2024

Satellite terminals and other equipment listed in category (4) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications, shall be deemed “residential consumer” if the equipment is designated EAR99 or classified under ECCN 5A992.c, 5A991.b.2, or 5A991.b.4 or, in the case of equipment that is not subject to the EAR, would be designated EAR99 if it were located in the United States or would meet the criteria for classification under ECCN 5A992.c, 5A991.b.2, or 5A991.b.4 if it were subject to the EAR. 

Date Updated: May 16, 2024

“Software required for effective consumer use” consists of software essential to the operation of the hardware listed in category (5) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications, including, for example, drivers and patches.  Operating systems are separately authorized in category (5) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications.

In addition, effective June 16, 2024, OFAC is amending the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications to exclude laptops, tablets, and personal computing devices with an “Adjusted Peak Performance” (“APP”) exceeding 1 Weighted TeraFLOP (WT).  After this change is effective, the only laptops, tablets, and other computing devices that may be exported to Iran are ones with an APP of 1 WT or less.

Date Updated: May 16, 2024

Yes.  Section 560.540(a)(1) of the ITSR authorizes the provision to Iran of fee-based cloud computing services that support the exchange of communications over the internet.  In addition, paragraph (a)(2)(i) of 31 CFR § 560.540 authorizes the provision to Iran of software that is incident to, or enables services incident to, the exchange of communications over the internet, and paragraph (a)(3) authorizes the provision to Iran of software described in the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications and services necessary for the operation of such software, in both cases provided that such software is designated EAR99 or classified by the U.S. Department of Commerce on the CCL under ECCN 5D992.c or, in the case of software that is not subject to the EAR, would be designated EAR99 if it were located in the United States or would meet the criteria for classification under ECCN 5D992.c if it were subject to the EAR.  Please see FAQs 1087–1089 for additional guidance. 

Date Updated: May 16, 2024

Yes.  Fee-based desktop publishing software and productivity software suites have been determined to fall within the scope of fee-based software that enables services incident to the exchange of communications as described in 31 CFR § 560.540(a)(2), provided that the software meets the additional criteria in those paragraphs (e.g., for software subject to the EAR, the software is designated EAR99 or is classified by the U.S. Department of Commerce on the Commerce Control List, 15 CFR part 774, supplement No. 1 (“CCL”) under ECCN 5D992.c).  By contrast, enterprise management software has been determined not to fall within the scope of fee-based software that enables services incident to the exchange of communications as described in 31 CFR § 560.540(a)(2).

Date Updated: May 16, 2024

No.  To qualify for 31 CFR § 560.540, all individual software items in a bundled package must fall within one of the 31 CFR § 560.540 authorizations.  If some software in a bundled package is authorized by 31 CFR § 560.540 but other software is not, the portion of the software falling outside the authorizations in 31 CFR § 560.540 would need to be otherwise exempt or authorized or would require a specific license for export.  A bundle of software that included exclusively software authorized by 31 CFR § 560.540 could be exported.  Please see FAQs 1087–1088 for guidance on certain types of cloud-based software authorized by 31 CFR § 560.540.

Date Updated: May 16, 2024

No.  While the exportation of certain accessories and peripherals specified in categories (1) and (5) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications is authorized under 31 CFR § 560.540(a)(3), the exportation to Iran of hardware parts or components is not.  Hardware that requires repair or replacement may be repaired or replaced outside Iran pursuant to 31 CFR § 560.540(a)(5) or (a)(7).  Requests for specific licenses to export to Iran parts or components, including replacement parts, will be considered on a case-by-case basis.

Date Updated: May 16, 2024

Yes.  Accessories for use in conjunction with hardware specified in categories (1) and (5) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications (the “31 CFR § 560.540 List), and peripherals for use in conjunction with hardware specified in category (5) of the same are authorized for export to Iran under 31 CFR § 560.540.  Authorized accessories for mobile phones include headsets, cases, holsters, mounts, chargers, docks, display protectors, cables, adapters, and batteries.  Authorized accessories for computers include keyboards and mice; authorized peripherals for computers include consumer disk drives and other data storage devices.  As set forth in a note to the 31 CFR § 560.540 List, for the purposes of the 31 CFR § 560.540 List, the term “consumer” refers to items that are: (1) generally available to the public by being sold, without restriction, from stock at retail selling points by means of any of the following: (a) over-the-counter transactions; (b) mail order transactions; (c) electronic transactions; or (d) telephone call transactions; and (2) designed for installation by the user without further substantial support by the supplier.

Date Updated: May 16, 2024

SSLs, as described in category (11) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications (“31 CFR § 560.540 List”) encompass “provisioning and verification software for Secure Socket Layer (SSL) certificates designated EAR99 or classified under ECCN 5D992.c, and services necessary for the operation of such software.”  Additional provisioning and verification software not subject to the EAR may be included under 31 CFR § 560.540’s authorization for, in relevant part, software not subject to the EAR that is exported, reexported, or provided, directly or indirectly, by a U.S. person located outside the United States, that is of a type described in the 31 CFR § 560.540 List, provided that it would be designated as EAR99 or would meet the criteria for classification under the relevant ECCN specified therein if it were subject to the EAR.

Date Updated: May 16, 2024

Yes.  Section 560.540(a)(3) authorizes the exportation of certain anti-virus, anti-malware, anti-tracking, anti-censorship software, and related services, as specified in categories (6), (7), and (9) of the31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications.

Date Updated: May 16, 2024

The exportation to Iran of apps that are designated EAR99 or classified under export control classification number (ECCN) 5D992.c, as specified in category (8) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications, is authorized under 31 CFR § 560.540(a)(3), including apps downloaded via online app stores, to the extent not authorized under 31 CFR § 560.540(a)(1) or (2) or exempt.

Date Updated: May 16, 2024

No.  Section 560.540 of the ITSR does not authorize the employment of persons in Iran to facilitate sales, the maintenance of a physical sales presence in Iran, or the utilization of Iranian marketing services.  However, the exportation of certain copy-ready advertising materials is exempt from the prohibitions of the ITSR to the extent they qualify as information or informational materials pursuant to 31 CFR § 560.210(c).  

Date Updated: May 16, 2024

U.S. sanctions on Iran do not impose any restrictions as to the use of the Farsi language. See FAQ 337.

Date Updated: May 16, 2024

Due diligence programs should be tailored to the particular risks encountered by exporters. 

As a general matter, companies selling fee-based services, software, or hardware authorized by 31 CFR § 560.540 should undertake reasonable, risk-based measures designed to ensure that they do not export their products to persons whose property and interests in property are blocked pursuant to any sanctions program administered by OFAC, regardless of whether the Government of Iran or other end-user appears on OFAC’s Specially Designated Nationals and Blocked Persons List or any of OFAC's other sanctions lists. 

See FAQ 1088 for more information regarding OFAC’s due diligence expectations for cloud-based service or software providers whose services and software support communications tools are authorized by 31 CFR § 560.540. 

Date Updated: May 16, 2024

In general, the payment requirements under 31 CFR § 560.540 are the same as for all other general licenses under the Iranian Transactions and Sanctions Regulations (ITSR).  Section 560.540(c) of the ITSR provides that U.S. depository institutions or U.S. registered brokers or dealers in securities may process transfers of funds from Iran or for or on behalf of a person in Iran that are in furtherance of a transaction authorized under 31 CFR § 560.540, provided the transfer is consistent with § 560.516, which does not allow debiting or crediting an Iranian account.  See 31 CFR § 560.516(a).

Date Updated: May 16, 2024

Yes.  Section 560.540 of the ITSR authorizes the exportation, reexportation, or provision to Iran and the importation into the United States by an individual entering the United States directly or indirectly from Iran, of hardware and software authorized by paragraphs 31 CFR § 560.540(a)(2) or (a)(3).  See Note 1 to paragraphs (a)(2) and (a)(3) of 31 CFR § 560.540.  Section 560.540 also authorizes the importation into the United States by an individual entering the United States, directly or indirectly, from Iran, of hardware or software authorized by 31 CFR § 560.540(a)(2) or (a)(3), provided the items were previously exported, reexported, or provided to Iran under an authorization issued pursuant to the ITSR.  See 31 CFR § 560.540(a)(5).  See also FAQ 1110.

Date Updated: May 16, 2024

Yes.  Section 560.540 of the ITSR continues to authorize the exportation, reexportation, or provision to Iran by U.S. persons located outside of the United States of certain specified hardware and software items that are not subject to the EAR.  See 31 CFR § 560.540(a)(2)(ii), (a)(3)(ii) and (iii).  Section 560.540 continues to extend this authorization to an entity owned or controlled by a U.S. person and established or maintained outside the United States (“a U.S.-owned or -controlled foreign entity”), subject to the conditions set forth in 31 CFR § 560.556.  For example, an overseas branch of a U.S. company or a U.S.-owned or -controlled foreign entity may export to Iran, from a location outside the United States, certain hardware or software that is not subject to the EAR (including foreign-origin hardware or software containing less than a de minimis amount of U.S. controlled content) if the hardware or software is within the scope of the 31 CFR § 560.540 authorization.  Section 560.540 also authorizes the exportation, reexportation, or provision of certain fee-based software that is not subject to the EAR because it is described in section 734.3(b)(3) of the EAR. 

Date Updated: May 16, 2024

Yes.  For purposes of the authorities administered by OFAC, 31 CFR § 560.540 authorizes the exportation, reexportation, or provision of certain hardware and software subject to the EAR by non-U.S. persons outside the United States.  See 31 CFR § 560.540(a)(2)(i) and (a)(3).  For example, a non-U.S. person manufacturer of smartphones that are (a) subject to the EAR because they contain more than a de minimis amount of U.S.-controlled content and (b) within the scope of the 31 CFR § 560.540 authorization may export the smartphones from its third-country manufacturing facility directly or indirectly to Iran.  See FAQs 1087–1089 and 1110.

Date Updated: May 16, 2024

If you require assistance interpreting the authorizations contained in 31 CFR § 560.540 and how they apply to your situation, please contact OFAC’s Compliance hotline or submit a request for interpretive guidance at the OFAC License Application Page.

Date Updated: May 16, 2024

No.  The 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications lists software, hardware, and related services determined to be “incident to communications” for purposes of the authorization in 31 CFR § 560.540(a)(3) of the ITSR.

Date Updated: May 16, 2024

Qualifying services under 31 CFR § 560.540(a)(1) are those that are “incident to the exchange of communications over the internet,” as well as cloud-based services in support of such services or of any other transaction authorized or exempt under the ITSR.  Qualifying software under 31 CFR § 560.540(a)(2) is software that is incident to, or enables services incident to, the exchange of communications over the internet, as well as certain cloud-based services.  In addition, qualifying software under 31 CFR § 560.540(a)(2) must meet the stated export control-related criteria.  Both paragraphs provide an illustrative but not exhaustive list of the types of services that are authorized: “instant messaging, chat and email, social networking, sharing of photos and movies, web browsing, blogging, social media platforms, collaboration platforms, video conferencing, e-gaming, e-learning platforms, automated translation, web maps, and user authentication services, as well as cloud-based services in support of the foregoing or of any other transaction authorized or exempt under the ITSR.

Qualifying services or software need not be specifically listed in the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications in order to be authorized by 31 CFR § 560.540(a)(1) or (a)(2), provided that they otherwise meet the requirements of 31 CFR § 560.540(a)(1) or (a)(2).

Date Updated: May 16, 2024

Yes, transactions that were authorized under 31 CFR § 560.540 of the ITSR as of May 16, 2024 or GL D 2 (as well as its predecessors, GLs D and D-1) continue to be authorized pursuant to the version of 31 CFR § 560.540 revised on May 17, 2024.  See FAQs 338–343 and 1110 for additional information on transactions authorized pursuant to 31 CFR § 560.540.  

Date Updated: May 16, 2024

All changes for the current calendar year are cumulatively available in the SDN List PDF file. The entire list may also be browsed using OFAC's Sanctions List Search Tool​. Cumulative changes for prior years back to 1994 are also available in ASCII format on the Archive of Changes to the SDN List page. The same link will take you to a *.PDF version of the file for calendar years back to 2001.

Date Updated: May 9, 2024

E.O. 14114 of December 22, 2023 amends E.O. 14068 to provide for additional prohibitions on the importation and entry into the United States of certain products.  It does so by maintaining the existing E.O. 14068 importation prohibitions in subsection 1(a)(i)(A) and identifying in subsections 1(a)(i)(B)–(D) additional types of products that may be prohibited upon the issuance of determinations, as described below. 

Subsection 1(a)(i)(B) authorizes the imposition of importation prohibitions on categories of fish, seafood, and preparations thereof, diamonds, and other products as may be determined, that were mined, extracted, produced, or manufactured wholly or in part in the Russian Federation, or harvested in waters under the jurisdiction of the Russian Federation or by Russia-flagged vessels, even if such products have been incorporated or substantially transformed into other products outside of the Russian Federation. 

Subsections 1(a)(i)(C) and (D) authorize the identification of additional types of products that would be subject to importation prohibitions under the order, upon a determination by the Secretary of the Treasury, in consultation with the Secretary of State, Secretary of Commerce, and Secretary of Homeland Security.

For additional information and guidance on the amendment to E.O. 14068, see FAQs 1155, 1156, 1157, 1164, 1165, and 1166. 
 

Date Updated: February 23, 2024

Yes.  Multiple Russia-related sanctions authorities authorize sanctions against non-U.S. persons that provide goods, services, or other support for Russia’s military-industrial complex.  For example, OFAC may block any person determined to operate or have operated in the defense and related materiel sector of the Russian Federation economy pursuant to Executive Order (E.O.) 14024 of April 15, 2021, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation.”  In addition, pursuant to E.O. 14024, OFAC may block persons determined to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of certain sanctionable activities enumerated in E.O. 14024 or any person whose property and interests in property are blocked pursuant to E.O. 14024.  OFAC also has robust targeting authorities pursuant to the Ukraine-/Russia-Related Sanctions Regulations (URSR), 31 C.F.R. part 589, which implement multiple authorities that could provide for the blocking of persons who engage in the provision of ammunition or other military goods to the Russian Federation, including persons determined to operate or have operated in the arms or related materiel sector of the Russian Federation economy, or those who have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of persons blocked pursuant to the URSR.  

Furthermore, E.O. 14024, as amended by E.O. 14114, authorizes the imposition of sanctions on foreign financial institutions that have conducted or facilitated certain transactions involving Russia’s military-industrial base.  For more information, see OFAC’s Advisory to Foreign Banks on Russia Sanctions Risks, and FAQs 1147, 1148, 1149, 1150 and 1151.

OFAC is prepared to use its broad targeting authorities against non-U.S. persons that provide ammunition or other support to the Russian Federation’s military-industrial complex, as well as private military companies (PMCs) or paramilitary groups participating in or otherwise supporting the Russian Federation’s unlawful and unjustified attack on Ukraine.  OFAC will continue to target Russia’s efforts to resupply its weapons and sustain its war of aggression against Ukraine, including any foreign persons who assist the Russian Federation in those efforts. 

OFAC and the Department of State have imposed numerous targeted sanctions on the Russian Federation’s military-industrial complex, including on State Corporation Rostec, the cornerstone of Russia’s defense-industrial base, and multiple other key firms.  In addition, the Department of State has identified persons that are part of, or operate for or on behalf of, the defense and intelligence sectors of the Government of the Russian Federation pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) (CAATSA 231 List of Specified Persons).  Persons determined to knowingly engage in a significant transaction with those identified on the CAATSA 231 List of Specified Persons are subject to five or more sanctions described in Section 235 of CAATSA.  The Department of Commerce’s Bureau of Industry and Security (BIS) has also imposed highly restrictive controls on the export and reexport of U.S.-origin and certain foreign-produced commodities, software, and technologies to the Russian Federation to cut off its access to inputs and products needed to sustain its military capabilities.  For more information on the impact of sanctions and export controls on Russia’s military-industrial complex, please see “OFAC-BIS Alert: Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex,” published on October 14, 2022 and BIS’s Common High Priority Items List. 

Date Updated: February 23, 2024

For the purposes of E.O. 14068, as amended by E.O. 14114, the Office of Foreign Assets Control anticipates publishing regulations defining these terms to include the following:

• “Russian Federation origin” – see FAQ 1019.
• “fish, seafood, and preparations thereof” – articles defined at Harmonized Tariff Schedule of the United States (HTSUS) subheadings 0301.11.00 to 0301.99.03; 0302.11.00 to 0302.99.00; 0303.11.00 to 0303.99.00; 0304.31.00 to 0304.99.91; 0305.20.20 to 0305.79.00; 0306.11.00 to 0306.99.01; 0307.11.00 to 0307.99.03; 0308.11.00 to 0308.90.01; 0309.10.05 to 0309.90.90; 1603.00.10; 1603.00.90; 1604.11.20 to 1604.32.40; 1605.10.05 to 1605.69.00; 0508.00.0000; 2301.20.0010; 2310.20.0090; 1504.10.20 to 1504.20.60; and 2106.90.9998, including any subsequent revisions to the list of HTSUS classifications. See FAQ 1157 for additional definitions of certain categories of fish, seafood, and preparations thereof.
• “alcoholic beverages” – articles defined at HTSUS subheadings 2203.00.00; 2204.10.00 to 2204.30.00; 2205.10.30 to 2205.90.60; 2206.00.15 to 2206.00.90; 2207.10.30 to 2207.20.00; and 2208.20.10 to 2208.90.80, including any subsequent revisions to the list of HTSUS classifications.
• “non-industrial diamonds” – articles defined at HTSUS subheadings 7102.31.00 and 7102.39.00, including any subsequent revisions to the list of HTSUS classifications.
• “diamonds” - includes any diamonds classifiable under HTSUS subheadings 7102.10, 7102.31, and 7102.39 and under any other subheadings of the Harmonized Tariff Schedule of the United States specified in determinations.
• “unsorted diamonds” – articles defined under HTSUS subheading 7102.10.
• “diamond jewelry” – articles defined under HTSUS heading 7113, incorporating diamonds.

With respect to the export prohibitions set forth in section 1(a)(ii) of E.O. 14068, please consult the U.S. Department of Commerce, Bureau of Industry and Security, for guidance.

Date Updated: February 23, 2024

Russia-related GL 6C (“Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials”) remains valid and authorizes, among other things, certain transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, ordinarily incident and necessary to (1) the production, manufacturing, sale, transport, or provision  of agricultural commodities, including products such as fish, seafood, or preparations thereof — to the extent they fall within the definition of agricultural commodities provided in GL 6C — to, from, or transiting the Russian Federation (see FAQ 979).  

However, GL 6C does not authorize any transactions prohibited by E.O. 14068, including transactions prohibited by the determination of December 22, 2023 (Seafood Determination).  In particular, E.O. 14068 prohibits the importation into the United States of, among other things, Russian Federation origin fish, seafood, and preparations thereof.  The Seafood Determination further prohibits the importation of salmon, cod, pollock, or crab produced wholly or in part in the Russian Federation, or harvested in waters under the jurisdiction of the Russian Federation or by Russia-flagged vessels, notwithstanding whether such salmon, cod, pollock, or crab has been incorporated or substantially transformed into another product outside of the Russian Federation.   As such, U.S. persons cannot rely on GL 6C for transactions that are for the importation into the United States of Russian Federation origin fish, seafood, or preparations thereof, or salmon, cod, pollock, or crab covered by the Seafood Determination, unless otherwise authorized by OFAC.  However, U.S. persons may continue to rely on GL 6C for transactions otherwise prohibited by E.O. 14024 involving agricultural commodities.

Date Updated: February 23, 2024

E.O. 14068 prohibits the following activities:

• the importation into the United States of the following products of Russian Federation origin:  fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds; and any other products of Russian Federation origin as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Commerce;
• the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of luxury goods, and any other items as may be determined by the Secretary of Commerce, in consultation with the Secretary of State and the Secretary of the Treasury, to any person located in the Russian Federation;
• new investment in any sector of the Russian Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, by a United States person, wherever located;
• the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation; and
• any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by sections 1(a)(i)-(iv) of E.O. 14068 if performed by a United States person or within the United States.

On December 22, 2023, E.O. 14068 was amended to provide for additional prohibitions on the importation and entry into the United States of certain categories of products.  See FAQ 1154 for additional information on how E.O. 14114 amends E.O. 14068.

Date Updated: February 23, 2024

Persons identified pursuant to E.O. 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy are not subject to prohibitions under E.O. 14024 unless those persons are also sanctioned pursuant to E.O. 14024.  For more information regarding Directive 3, please review applicable OFAC public guidance, such as FAQ 411.

E.O. 14024 provides for blocking sanctions on persons operating in the technology sector or the defense and related materiel sector of the Russian Federation economy, or any other sectors determined by the Secretary of the Treasury, in consultation with the Secretary of State.  The identification of a sector pursuant to E.O. 14024 provides notice that persons operating in the identified sector are exposed to sanctions risk; however, such identification does not automatically block all persons operating in the sector.  Only persons designated pursuant to E.O. 14024 for operating in the defense and related materiel sector of the Russian economy (or any other sector identified under the E.O.) are subject to blocking sanctions and will appear on the SDN List.

E.O. 14024, as amended by E.O. 14114, also authorizes the imposition of sanctions on foreign financial institutions that have conducted or facilitated certain transactions involving Russia’s military-industrial base.  See FAQs 1147, 1148, 1149, 1150 and 1151 for information. 

Date Updated: February 23, 2024

E.O. 14024 establishes a new national emergency under which sanctions may be imposed against individuals and entities furthering specified harmful foreign activities of the Russian Federation.  This national emergency is separate from the national emergency relating to the crisis in Ukraine, declared in E.O. 13660 and further addressed in E.O.s 13661, 13662, 13685, and 13849.   E.O. 14024 addresses national security threats posed by specified harmful foreign activities of the Russian Federation, including:  its efforts to undermine the conduct of free and fair democratic elections and democratic institutions in the United States and its allies and partners; engaging in and facilitating malicious cyber-enabled activities against the United States and its allies and partners; fostering and using transnational corruption to influence foreign governments; pursuing extraterritorial activities targeting dissidents or journalists; undermining security in countries and regions important to United States national security; and violating well-established principles of international law, including respect for the territorial integrity of states. 

Like any other blocking Executive order, E.O. 14024 permits the United States to impose blocking and short-of-blocking sanctions.  The Office of Foreign Assets Control (OFAC) issued several directives under E.O. 14024 specifying certain prohibitions relating to persons determined to be subject to the applicable directive.  OFAC recommends reviewing the sanctions lists maintained by OFAC, including the Specially Designated Nationals and Blocked Persons List (SDN List), the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List), and the Non-SDN Menu-Based Sanctions List (NS-MBS List), to determine which sanctions are applicable.

On December 22, 2023, the President issued E.O. 14114, “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities,” which amended E.O. 14024 to further address the Russian Federation’s continued use of its military-industrial base to aid its effort to undermine security in countries and regions important to United States national security.  See FAQ 1147 for information on how E.O. 14114 amended E.O. 14024.

Date Updated: February 23, 2024

The general license at § 510.522 of the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR), authorizes news reporting organizations that are U.S. persons, and their U.S. person employees to engage in certain transactions in North Korea, provided that such transactions are ordinarily incident and necessary to their journalistic activities or the establishment or operation of a news bureau in North Korea.  The authorized activities include: hiring and compensating support staff, logistics personnel, or other office personnel as needed; leasing or renting office space; renting and using telecommunications facilities; and, under certain conditions, exporting and reexporting to North Korea, and subsequently reexporting from North Korea, equipment that is not subject to the Export Administration Regulations (15 CFR parts 730 through 774) (EAR).  Exports and reexports of items that are subject to the EAR must be authorized pursuant to a license or license exception (for example, License Exception TMP) issued by BIS.

While certain transactions ordinarily incident to travel and certain exports and imports of information and informational materials are exempt under the International Emergency Economic Powers Act, 50 U.S.C. § 1702(b) (IEEPA), these exemptions do not apply to transactions prohibited pursuant to the United Nations Participation Act.

Moreover, as of September 1, 2017, U.S. passports are invalid for travel into, in, or through North Korea. However, in limited circumstances, applicants may be eligible for a Special Validation Passport from the State Department that will allow them to travel for specific purposes. See travel.state.gov for additional details.

Date Updated: February 15, 2024

Yes. Section 510.512(a) of the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR), authorizes NGOs that have filed the report specified in § 510.512 to conduct transactions that are ordinarily incident and necessary to the following activities:

1. activities to support humanitarian projects to meet basic human needs,, including disaster, drought, or flood relief; food, nutrition, or medicine distribution; the provision of health services; assistance for vulnerable or displaced populations, including individuals with disabilities and the elderly; and environmental programs and (the foregoing activities continue to include the distribution of clean water, bottled drinking water, and clothing, and provision of shelter);  
2. activities to support democracy building, including rule of law, citizen participation, government accountability, universal human rights and fundamental freedoms, access to information, and civil society development projects;
3. activities to support education at or below a secondary school level, including combating illiteracy, increasing access to education at the primary or secondary school level, and assisting education reform projects, provided that such education excludes the subjects of math, sciences, technology, engineering, and computer programming;
4. activities to support non-commercial development projects directly benefiting civilians, including those related to health, food security, and water and sanitation;  
5. activities to support environmental and natural resource protection, including the preservation and protection of threatened or endangered species, responsible and transparent management of natural resources, and the remediation of pollution or other environmental damage; and
6. activities to support disarmament, demobilization, and reintegration (DDR) programs and peacebuilding, conflict prevent, and conflict resolution programs.

Such ordinarily incident and necessary transactions may include payment of reasonable and customary taxes, fees, and import duties to, and purchase of receipt of permits, licenses, or public utility services from the Government of North Korea.

In addition, for items that are not subject to the Export Administration Regulations (EAR), § 510.512(a) authorizes the export or reexport of items ordinarily incident and necessary to the activities described above, provided the items would be designated as EAR99 if located in the United States.  For more information about OFAC and Commerce licensing requirements relating to the export or reexport of items that are subject to the EAR to North Korea, please see FAQ 459.

In most instances, exporters or reexporters no longer need to obtain licenses from both the Department of Commerce’s Bureau of Industry and Security (BIS) and OFAC to engage in transactions related to the export or reexport of items to persons blocked pursuant to the NKSR.  Section 510.520 authorizes transactions that are ordinarily incident to the exportation or reexportation of items to North Korea if the exportation or reexportation of such items is authorized by BIS.  Authorization from BIS is required to export or reexport any item subject to the EAR to North Korea, except food and medicine classified as EAR99 (see also the general license § 510.521 for transactions related to the exportation or reexportation of qualifying food and medicine to North Korea that are not subject to the EAR).

Additionally, § 510.512(c) explicitly authorizes U.S. depository institutions, U.S.-registered brokers or dealers in securities, and U.S.-registered money transmitters to process transfers of funds on behalf of U.S. or third-country NGOs, including to or from North Korea, in support of the activities described above. 

Date Updated: February 15, 2024 
 

None.  E.O. 13722 prohibits the exportation or reexportation, from the United States, or by a United States person, of any goods, services, or technology to North Korea, unless authorized or exempt.  BIS maintains authority to license exports and reexports of items (i.e., commodities, software, or technology) subject to the Export Administration Regulations (15 CFR parts 730 through 774) to North Korea.   Section 510.520 provides that persons exporting or reexporting items to North Korea do not need to obtain a specific license from OFAC to engage in transactions ordinarily incident to such export or reexport or to service such items outside of North Korea, if the export or reexport has been licensed or otherwise authorized by BIS, even if the authorized export or reexport involves a person on the List of Specially Designated Nationals and Blocked Persons (SDN List), the Government of North Korea, or the Workers’ Party of Korea. 

Date Updated: February 15, 2024

OFAC expects to use its discretion to target in particular those who operate corruptly in the gold or other identified sectors of the Venezuela economy, and not those who are operating legitimately in such sectors. This includes, for example, persons engaging in dishonest or fraudulent conduct, illicit activity, or deceptive transactions within Venezuela’s gold sector or other identified Venezuela sectors, with the purpose or effect of misappropriating Venezuelan resources in those sectors for personal, professional, or political gain.  

Date Updated: February 02, 2024

For the purposes of the Seafood Determination, OFAC anticipates publishing regulations defining these terms to include articles defined at the following Harmonized Tariff Schedule of the United States (HTSUS) subheadings: 
•    “Salmon:” articles defined at HTSUS subheadings 0302.13.0013, 0302.13.0014, 0302.13.0022, 0302.13.0032, 0302.13.0042, 0302.13.0053, 0302.13.0054, 0302.13.0062, 0302.14.0003, 0302.14.0004, 0302.14.0062, 0303.11.0000, 0303.12.0012, 0303.12.0022, 0303.12.0032, 0303.12.0052, 0303.12.0062, 0303.13.0000, 0303.91.4040, 0304.41.00, 0304.41.0010, 0304.41.0020, 0304.41.0090, 0304.52.00, 0304.52.0010, 0304.52.0015, 0304.52.0020, 0304.52.0090, 0304.81.1000, 0304.81.5010, 0304.81.5090, 0305.20.4020, 0305.41.0000, 0305.69.4000, 1604.11.2020, 1604.11.2030, 1604.11.2090, 1604.11.4010, 1604.11.4020, 1604.11.4030, 1604.11.4040, 1604.11.4050, including any subsequent revisions to the list of HTSUS classifications.
•    “Cod:” articles defined at HTSUS subheadings 0302.51.0010, 0302.51.0090, 0303.63.0010, 0303.63.0090, 0304.44.0010, 0304.44.0015, 0304.53.0010, 0304.53.0015, 0304.71.1000, 0304.71.5000, 0304.95.1010, 0304.95.1015, 0304.95.1020, 0305.32.0010, 0305.32.0090, 0305.51.0000, 0305.62.0010, 0305.62.0025, 0305.62.0030, 0305.62.0045, 0305.62.0050, 0305.62.0060, 0305.62.0070, 0305.62.0080, including any subsequent revisions to the list of HTSUS classifications.
•    “Pollock:” articles defined at HTSUS subheadings 0302.55.1100, 0302.55.5000, 0302.59.5010, 0303.67.0000, 0304.44.0025, 0304.53.0025, 0304.75.1000, 0304.75.5000, 0304.79.1010, 0304.94.1005, 0304.94.1010, 0304.94.1090, 0304.94.9000, 0304.95.1030, 0305.69.1022, 0305.69.1042, 1604.19.1000, 1604.19.2500, including any subsequent revisions to the list of HTSUS classifications.
•    “Crab:” articles defined at HTSUS subheadings 0306.14.2000, 0306.14.40, 0306.14.4003, 0306.14.4006, 0306.14.4009, 0306.14.4012, 0306.14.4015, 0306.14.4020, 0306.14.4030, 0306.14.4090, 0306.33.2000, 0306.33.4000, 0306.93.2000, 0306.93.4000, 1605.10.0510, 1605.10.0590, 1605.10.2010, 1605.10.2022, 1605.10.2025, 1605.10.2030, 1605.10.2051, 1605.10.2059, 1605.10.2090, 1605.10.4002, 1605.10.4005, 1605.10.4010, 1605.10.4015, 1605.10.4025, 1605.10.4030, 1605.10.4035, 1605.10.4040, 1605.10.6010, 1605.10.6090, including any subsequent revisions to the list of HTSUS classifications.
Additionally, these terms apply to products of salmon, cod, pollack and crab classified under the HTSUS subheadings 0301.99.0390, 0302.59.1100, 0304.95.1005, 0304.95.1090, 0304.99.1104, 0304.99.1109, 0304.99.1183, 0305.20.4065, 0305.39.6180, 0305.49.4020, 0305.49.4045, 0305.59.0001, 0305.72.0000, 0305.79.0000, 1603.00.9090, 1604.19.2200, 1604.19.3200, 1604.19.4100, 1604.19.5100, 1604.19.6100, 1604.19.8200, 1604.20.0510, 1604.20.0590, 1604.20.1000, 1604.20.1500, 1604.20.2000, 1604.20.2500, 1604.20.3000, 1604.20.4000, 1604.20.5010, 1604.20.5090, 1604.20.6010, 1604.20.6090, including any subsequent revisions to the list of HTSUS classifications.

Date Updated: January 18, 2024

The determination of June 28, 2022 (as amended by the determination of December 22, 2023) issued pursuant to subsection 1(a)(i)(A) of amended E.O. 14068, “Prohibitions Related to Imports of Gold of Russian Federation Origin,” prohibits the importation into the United States of gold of Russian Federation origin.  Please note that per the determination, the importation into the United States of gold of Russian Federation origin that was located outside of the Russian Federation prior to June 28, 2022 is not prohibited.  For information regarding the term “Russian Federation origin,” please see FAQ 1019.

Date Updated: December 22, 2023

With respect to foreign financial institutions 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), including Public Joint Stock Company Sberbank of Russia, obligations under this directive apply to U.S. financial institutions only.  U.S. individuals and companies that are not “U.S. financial institutions,” as defined in the Russia-related CAPTA Directive, are not prohibited from processing transactions involving foreign financial institutions solely subject to the Russia-related CAPTA Directive.  

With respect to the Russian financial institutions blocked on February 22 and 24, 2022 pursuant to E.O. 14024, General Licenses (GLs) 3 and 11 authorized U.S. persons to engage in transactions ordinarily incident and necessary to terminate their relationship with specified blocked Russian financial institutions, including withdrawing funds and securities, cancelling letters of credit, and amending or cancelling performance guarantees.  For additional information, please see FAQ 975.  Upon the respective expiration of GLs 3 and 11, U.S. persons were prohibited from transacting with the blocked Russian financial institutions, unless exempt or authorized by OFAC. 

Date Updated: December 22, 2023

General License 3I (GL 3I) authorizes U.S. persons to engage in all transactions related to, the provision of financing for, and other dealings in the bonds specified in the Annex to GL 3I (GL 3I Bonds) that would be prohibited by subsection 1(a)(iii) of Executive Order (E.O.) 13808 or by E.O. 13850, each as amended by E.O. 13857, or by E.O. 13884, as collectively incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR).  The authorization in GL 3I includes, for example, engaging in transactions related to the receipt and processing of interest or principal payments, and acting as a custodian for U.S. and non-U.S. persons’ holdings in GL 3I Bonds.  GL 3I also authorizes divestment of the GL 3I Bonds, including, on or after October 18, 2023, to other U.S. persons.

Paragraph (b) of GL 3I authorizes all transactions prohibited by subsection 1(a)(iii) of E.O. 13808 or by E.O. 13850, each as amended by E.O. 13857, or by E.O. 13884, that are ordinarily incident and necessary to facilitating, clearing, and settling trades of holdings in the GL 3I Bonds, provided such trades were placed prior to 4:00 p.m. eastern standard time on February 1, 2019; this authorization aims to ensure that trades that were placed prior to February 1, 2019, are allowed to settle in the ordinary course.

Paragraph (d) of GL 3I authorizes all transactions related to, the provision of financing for, and other dealings in bonds that were issued both (i) prior to August 25, 2017 (the effective date of E.O. 13808), and (ii) by U.S. person entities owned or controlled, directly or indirectly, by the Government of Venezuela, other than PDV Holding, Inc., CITGO Holding, Inc., and any of their subsidiaries, that would be prohibited by E.O. 13808 or E.O. 13850, each as amended, or by E.O. 13884.

Date Updated: October 18, 2023

General License (GL) 9H authorizes U.S. persons to engage in all transactions prohibited by subsection 1(a)(iii) of Executive Order (E.O.) 13808 or by E.O. 13850, each as amended by E.O. 13857, or by E.O. 13884, as collectively incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), that are ordinarily incident and necessary to dealings in any debt of, or equity in, PdVSA, or any entity directly or indirectly owned 50 percent or more by PdVSA, that was issued prior to August 25, 2017 (together, “PdVSA Securities”).  This includes bonds issued by PDV Holding, Inc. and CITGO Holding, Inc., or any of their subsidiaries.  The authorization in GL 9H includes, for example, engaging in transactions related to the receipt and processing of interest or principal payments, and acting as a custodian for U.S. and non-U.S. persons’ holdings in PdVSA Securities.  GL 9H also authorizes divestment of the PdVSA Securities, including, on or after October 18, 2023, to other U.S. persons.

Paragraph (c) of GL 9H authorizes all transactions prohibited by subsection 1(a)(iii) of E.O. 13808 or by E.O. 13850, each as amended by E.O. 13857, or by E.O. 13884, that are ordinarily incident and necessary to facilitating, clearing, and settling trades of holdings in PdVSA Securities, provided such trades were placed prior to 4:00 p.m. eastern standard time on January 28, 2019; this authorization aims to ensure that trades that were placed prior to the imposition of blocking sanctions on PdVSA are allowed to settle in the ordinary course. 

Date Updated: October 18, 2023

Yes.  The prohibitions apply to services provided to a company located in the Russian Federation (the “Russian company”) by any U.S. person, including the Russian company’s U.S. subsidiary.

Date Updated: May 19, 2023 

Not necessarily.  Under the determinations, U.S. persons are prohibited from exporting, reexporting, selling, or supplying, directly or indirectly: management consulting; trust and corporate formation services; accounting services; quantum computing services; architecture services; and engineering services to persons located in the Russian Federation.  Thus, U.S. persons are prohibited from providing these services to companies located in the Russian Federation (“Russian companies”) in their capacity as employees.  However, the determinations do not prohibit U.S. persons from providing other services not covered by these determinations as part of their employment by Russian companies.

In addition, please note that the determinations exclude from the scope of the aforementioned services:  (1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a United States person; and (2) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person.

Date Updated: May 19, 2023 

No, provided that the provision of services is not an indirect export to a person located in the Russian Federation.  For the purposes of these determinations, OFAC interprets the “indirect” provision of the prohibited services to include when the benefit of the services is ultimately received by a “person located in the Russian Federation.”

In contrast, OFAC would not consider to be prohibited the provision of services to a non-Russian company that has a physical presence and operations outside of the Russian Federation, including such a company owned or controlled by persons located in the Russian Federation, provided that the services will not be further exported or reexported to persons located in the Russian Federation.

For example, the following scenarios describe services that would be prohibited under the determination:

• A U.S. corporate service provider administers a trust established under the laws of a U.S. state, where the trust exists to hold, sell, or purchase assets on behalf of a settlor, trustor, or beneficiary who is an individual ordinarily resident in Russia. 
• A U.S. corporate service provider registers a limited liability company in a third country on behalf of an individual ordinarily resident in Russia for the purpose of holding real estate assets, and this company has no other physical presence or operations in the third country. 

The following scenarios illustrate services to a non-Russian subsidiary of a Russian person that would not be prohibited under the determination:

• A U.S. accounting firm provides tax advisory and preparation services to the U.S. subsidiary of a Russian company.  This U.S. subsidiary has an office and employees in the United States and conducts business in the United States, and the services will not be exported or reexported to the Russian parent company.
• A U.S. management consulting firm provides strategic business advice to the subsidiary of a Russian company located in a third country.  This subsidiary has an office and employees in the third country and conducts business in this third country, and the services will not be reexported to the Russian parent company.

Date Updated: May 19, 2023 

No, the Russia-related Sovereign Transactions Directive does not prohibit trading in the secondary markets for debt or equity of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, “Directive 4 entities”), provided that no Directive 4 entity is a counterparty to such a transaction.  Please note, however, that Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), prohibits U.S. financial institutions from participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Directive 4 entities.  However, the “new investment” prohibitions of E.O.14066, E.O. 14068, and E.O. 14071 prohibit U.S. persons from purchasing debt and equity securities issued by an entity in the Russian Federation.  Please see FAQ 1054.

Date Updated: May 19, 2023

No.  Although the prohibitions of the Russia-related Sovereign Transactions Directive effectively immobilize any assets of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, the “Directive 4 entities”) that are held in the United States or by U.S. persons, wherever located, the Russia-related Sovereign Transactions Directive does not impose blocking sanctions on the Directive 4 entities.  Rather, U.S. persons must reject transactions involving the Directive 4 entities, unless exempt or authorized by OFAC.

Date Updated: May 19, 2023

No. The Russia-related Sovereign Transactions Directive prohibits U.S. persons from engaging in any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities.  Effective February 28, 2022, U.S. persons may not engage in any transactions involving these entities unless exempt or authorized by the Office of Foreign Assets Control (OFAC), including debiting funds from restricted accounts.  This includes both direct and indirect transactions. The Russia-related Sovereign Transactions Directive also prohibits: (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive; and (2) any conspiracy formed to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive.  

In light of the current economic situation in Russia, U.S. persons should be on alert for nonroutine foreign exchange transactions that may indirectly involve entities subject to the Russia-related Sovereign Transactions Directive, including transactions that are inconsistent with activity over the 12 months prior to February 28, 2022. For example, the Central Bank of the Russian Federation may seek to use import or export companies to engage in foreign exchange transactions on its behalf and obfuscate its involvement. U.S. persons should also exercise caution in engaging in foreign exchange transactions on the Moscow Exchange given the current heightened risk that the Central Bank of the Russia Federation could be a counterparty to such transactions.

Date Updated: May 19, 2023

No.

Date Updated: May 19, 2023

The Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation are subject to several restrictions under the following directives:

• Effective February 28, 2022, Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive), prohibits U.S. persons from engaging in any transaction involving these entities, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities.  The Russia-related Sovereign Transactions Directive was amended on May 19, 2023 to include a reporting requirement. (see FAQ 998)
• Pursuant to Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), the following activities by a U.S. financial institution are prohibited:
  • As of June 14, 2021, participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; 
  • As of June 14, 2021, lending ruble or non-ruble denominated funds to the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; and
  • As of March 1, 2022, participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (see FAQ 888).

• Effective August 19, 2019, the Russia-Related Directive (the “CBW Act Directive”) prohibits U.S. banks from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign and also prohibits U.S. banks from lending non-ruble denominated funds to the Russian sovereign.  The CBW Act Directive defines the term “Russian sovereign” as any ministry, agency, or sovereign fund of the Russian Federation, including the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance of the Russian Federation (see FAQs 675 and 676).   

The Russia-related Sovereign Transactions Directive includes prohibitions more expansive than the Russia-related Sovereign Debt Directive and the CBW Act Directive; however, it is important to note that each directive operates independently of the others and may have different effective dates.  Transactions involving these entities must comply with all three directives described above.

Date Updated: May 19, 2023

The Russia-related Sovereign Transactions Directive prohibits U.S. persons from engaging in any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, “Directive 4 entities”), including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities.  Effective February 28, 2022, U.S. persons may not engage in any transactions involving these entities unless exempt or authorized by the Office of Foreign Assets Control (OFAC).  This includes both direct and indirect transactions involving any Directive 4 entity.  Prohibited transactions include trade or financial transactions and other dealings in which U.S. persons may not engage unless exempt or expressly authorized by OFAC.

The Russia-related Sovereign Transactions Directive also prohibits: (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive; and (2) any conspiracy formed to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive.

This action effectively immobilizes any assets of the Directive 4 entities that are held in the United States or by U.S. persons, wherever located, unless exempt or authorized by OFAC.  Effective February 28, 2022, U.S. financial institutions must reject transactions involving any Directive 4 entity, unless exempt or authorized by OFAC, and file a report within 10 business days in accordance with 31 CFR § 501.604.  OFAC issued general licenses that authorize certain limited transactions involving the Directive 4 entities (see FAQ 999).

On May 19, 2023, OFAC amended Directive 4 to require U.S. persons to submit a report to OFACreport@treasury.gov on or before June 18, 2023, and annually thereafter by June 30, regarding property in their possession or control in which any Directive 4 entity has an interest of any nature whatsoever, direct or indirect.  This reporting requirement is intended to identify assets of Directive 4 entities held by U.S. persons as of May 31, 2023, and annually thereafter, and is separate from the above-noted requirement under 31 CFR 501.604 to file reports on rejected transactions involving any Directive 4 entity. 

Entities determined to be subject to the Russia-related Sovereign Transactions Directive are listed on OFAC’s Non-SDN Menu-Based Sanctions (NS-MBS) List.

Date Updated: May 19, 2023

The national emergency declared with respect to the Government of Sudan in Executive Order (E.O.) 13067 of November 3, 1997 — as expanded upon in scope by subsequent E.O.s — remains in effect.  As detailed below, certain sanctions have been imposed and others have been lifted pursuant to that national emergency, in response to developments in Sudan. 

The following sanctions authorities are in effect with respect to Sudan:

• E.O. 14098 of May 4, 2023, among other things, authorizes the imposition of sanctions on foreign persons to address the situation in Sudan following the military’s seizure of power in October 2021 and the outbreak of inter-service fighting in April 2023, and to support a transition to democracy and civilian transitional government in Sudan.
• E.O. 13400 of April 26, 2006 imposes sanctions on individuals and entities in connection with the conflict in Darfur and, in part, implements sanctions with respect to that conflict adopted by the United Nations Security Council. 

The following sanctions authorities are no longer in effect with respect to Sudan:

• Effective October 12, 2017, sections 1 and 2 of E.O. 13067 of November 3, 1997 and all of E.O. 13412 of October 13, 2006 were revoked, pursuant to E.O. 13761 of January 13, 2017, as amended by E.O. 13804 of July 11, 2017.  To reflect this revocation of authorities, OFAC removed the Sudanese Sanctions Regulations, 31 CFR part 538 (SSR) from the Code of Federal Regulations (CFR) on June 29, 2018.  U.S. persons are not broadly prohibited from engaging in transactions with respect to Sudan or the Government of Sudan that were previously prohibited solely by the SSR. In addition, following the revocation of sections 1 and 2 of E.O. 13067 and E.O. 13412, persons designated solely pursuant to the blocking authorities of E.O. 13067 or E.O. 13412 were removed from OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List).
• The determination regarding Sudan as a State Sponsor of Terrorism was rescinded on December 14, 2020.  Accordingly, Sudan is no longer subject to prohibitions under the Terrorism List Governments Sanctions Regulations, 31 CFR part 596 (TLGSR), or section 906(a)(1) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (22 U.S.C. 7205). 

Note that the revocation of the aforementioned sanctions authorities does not affect past, present, or future OFAC enforcement investigations or actions associated with any apparent violations of the SSR that occurred prior to October 12, 2017 or of the TLGSR prior to December 14, 2020. 

Date Updated: May 4, 2023

No.  A specific license from OFAC is not required to initiate or continue U.S. legal proceedings against a person designated or blocked pursuant to the Venezuela Sanctions Regulations, 31 CFR part 591 (VSR), or for a U.S. court, or its personnel, to hear such a case.  Similarly, creditors may file for writs of attachment without the need for OFAC authorization for matters involving property blocked under the VSR.

However, a specific license from OFAC is required for the entry into a settlement agreement, or for the enforcement of any lien, judgment, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property blocked pursuant to the VSR.

For additional information, see 31 CFR §§ 591.309, 591.310, 591.407 and 591.506.

With respect to the specific facts and circumstances in Crystallex Int’l Corp. v. Bolivarian Republic of Venezuela, 17-mc-00151, before the U.S. District Court for the District of Delaware, please see Frequently Asked Question (FAQ) 1123.  For information on general licenses that may authorize certain settlement negotiations involving persons designated or blocked pursuant to the VSR, please see OFAC FAQs 1124 and 1125.  

Date Updated: May 01, 2023

No. GL 1C does not authorize the export of any goods, technology, or services directly or indirectly to the Federal Security Service or any other blocked person, except for the limited purposes of complying with rules and regulations administered by, and certain actions and investigations involving, the Federal Security Service or requesting certain licenses or authorizations for the importation, distribution, or use of information technology products in the Russian Federation.

Date Updated: April 27, 2023

GL 1C only authorizes certain transactions and activities with the Federal Security Service acting in its administrative and law enforcement capacities. The GL was issued in order to ensure that U.S. persons engaging in certain business activities in Russia that are not otherwise prohibited are not unduly impacted. All other transactions and activities involving any property subject to U.S. jurisdiction or within the possession or control of U.S. persons in which the Federal Security Service has an interest, including all other transactions and activities directly or indirectly with the Federal Security Service, remain prohibited unless exempt or otherwise authorized by OFAC.

Date Updated: April 27, 2023

GL 1C authorizes transactions with the Federal Security Service (a.k.a. Federalnaya Sluzhba Bezopasnosti) (a.k.a. FSB) that are ordinarily incident and necessary to requesting, receiving, utilizing, paying for, or dealing in certain licenses and authorizations for the importation, distribution, or use of certain information technology products in the Russian Federation.  It also authorizes transactions ordinarily incident and necessary to compliance with rules and regulations administered by, and certain actions or investigations involving, the Federal Security Service.

This general license does not authorize U.S. persons to engage in transactions with the Federal Security Service, except for the limited purposes described above, nor does it authorize the exportation, reexportation, sale or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any goods, services, or technology to the so-called “Donetsk People’s Republic” or “Luhansk People’s Republic” (DNR/LNR) regions of Ukraine, or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, pursuant to Executive Order 14065, or to the Crimea region of Ukraine.

Date Updated: April 27, 2023

No, provided that (i) such funds are not specifically intended for new projects or operations in the Russian Federation and (ii) the entity located outside the Russian Federation derives less than 50 percent of its revenues from its investments in the Russian Federation.  

For the purposes of assessing the foregoing, U.S. persons, including U.S. financial institutions, may reasonably rely upon the information available to them in the ordinary course of business, including publicly available information such as an entity’s most recent quarterly or annual report.  For the purposes of determining the percentage of revenues derived from investments in the Russian Federation, revenues derived from the commercial sale of goods or services by an entity located outside of the Russian Federation to persons in the Russian Federation should not be included.  This approach is consistent with the guidance provided by the Office of Foreign Assets Control (OFAC) in FAQ 1049, which clarifies that OFAC does not consider the commercial sale of goods or services to persons in the Russian Federation by an entity located outside the Russian Federation to be new investment in the Russian Federation for purposes of the respective E.O. prohibitions. 

Unless exempt or otherwise authorized by OFAC, examples of transactions that OFAC considers to be “new investment” for the purposes of the respective E.O. prohibitions include:

• The lending of funds to a special purpose vehicle established outside of the Russian Federation by a Russian entity for the purpose of raising funds intended to support new or expanded physical operations in the Russian Federation. 
• The purchase (including on the secondary markets) of a debt or equity interest in an entity located outside of the Russian Federation that derives 50 percent or more of its revenues from its ownership of a subsidiary located in the Russian Federation (e.g., through dividends paid up by the Russian subsidiary to the non-Russian parent company).  
• The purchase (including on the secondary markets) of a debt or equity interest in an entity located outside of the Russian Federation that derives 50 percent or more of its revenues from its ownership of real estate, a mine, or other physical property located in the Russian Federation. 

OFAC notes, however, the new investment prohibitions of the respective E.O.s do not prohibit U.S. persons from selling or divesting debt or equity securities issued by such entities to a non-U.S. person.  Moreover, U.S. financial institutions may clear and settle, or otherwise serve as market intermediaries in, such divestment transactions on the secondary market — including transactions between non-U.S. persons.  For the purposes of assessing whether certain purchases of debt or equity of an entity are permissible, U.S. financial institutions, including securities exchanges and other market intermediaries and participants, may reasonably rely upon the information available to them in the ordinary course of business.  

Examples of transactions that OFAC does not consider to be “new investment” for the purposes of the respective E.O. prohibitions include:

• The purchase (including on the secondary markets) of a debt or equity interest in an entity located outside of the Russian Federation provided that the entity derives less than 50 percent of its revenues from its ownership of a subsidiary or physical operation located in the Russian Federation. 
• The purchase (including on the secondary markets) of a debt or equity interest in an entity located outside of the Russian Federation whose revenue is exclusively derived from the commercial sale of goods or services to persons located in the Russian Federation.
• Activities that would be considered “maintenance” pursuant to FAQ 1050.  

Date Updated: January 17, 2023

Yes, the respective E.O.s prohibit U.S. persons from purchasing both new and existing debt and equity securities issued by an entity in the Russian Federation.  However, the new investment prohibitions of the respective E.O.s do not prohibit U.S. persons from selling or divesting debt or equity securities issued by an entity in the Russian Federation to a non-U.S. person (see FAQ 1049), including purchases of such debt or equity securities if ordinarily incident and necessary to the divestment or transfer of the debt or equity securities to a non-U.S. person.  U.S. financial institutions may clear and settle, or otherwise serve as market intermediaries in, divestment transactions on the secondary market—including transactions between non-U.S. persons.  

Please note that U.S. persons are not required to divest such securities and may continue to hold such previously acquired securities.  Moreover, the conversion of depositary receipts to underlying local shares of non-sanctioned Russian issuers would not be considered a prohibited “new investment” in the Russian Federation under the respective E.O.s.  

Additionally, the purchase of shares in a U.S. fund would not be considered a prohibited “new investment” under the respective E.O.s, unless the fund’s holdings of debt or equity securities issued by entities in the Russian Federation represent a 50 percent or more share by value of the fund.  Generally, the fund may also divest itself of these prohibited holdings.   

Date Updated: January 17, 2023

Unless otherwise authorized, U.S. persons may not buy or sell debt or equity of the Russian financial institutions blocked pursuant to Executive Order (E.O.) 14024.  Accordingly, a U.S. fund may not buy, sell, or otherwise engage in transactions related to debt or equity of such blocked Russian financial institutions, and must block such holdings, unless exempt or otherwise authorized by the Office of Foreign Assets Control (OFAC).  A U.S. fund that contains such blocked holdings generally is not itself considered a blocked entity unless such blocked holdings represent a 50 percent or more share by value of the fund.  If such blocked holdings do not represent a 50 percent or more share by value of the fund, U.S. persons may continue to invest in it, and the fund is not considered blocked.  The fund may divest itself of blocked holdings to the extent authorized by OFAC.

Date Updated: January 17, 2023

GL 21B authorizes all activities otherwise prohibited by the Global Terrorism Sanctions Regulations (GTSR), 31 CFR part 594, that are ordinarily incident and necessary to the limited safety and environmental activities described in paragraph (a) of GL 21B involving certain blocked persons and vessels through 12:01 a.m. eastern daylight time, April 13, 2023.  GL 21B does not authorize the offloading of any cargo onboard any of the blocked vessels listed in GL 21B, and any payment of claims to or for the benefit of any blocked persons or vessels would require a specific license from OFAC.  

After the expiration of GL 21B, U.S. persons will be prohibited from engaging in any transactions with the blocked persons or vessels listed in GL 21B, unless otherwise exempt or authorized by OFAC.  U.S. persons unable to conclude transactions authorized by GL 21B before 12:01 a.m. eastern daylight time, April 13, 2023, are encouraged to seek guidance from OFAC.  

Non-U.S. persons, including foreign financial institutions, generally do not risk exposure to sanctions for engaging in transactions with blocked persons where those transactions would not require a specific license if engaged in by a U.S. person.  Non-U.S. persons unable to conclude transactions authorized by GL 21B before 12:01 a.m. eastern daylight time, April 13, 2023, are encouraged to seek guidance from OFAC.

Date Updated: January 12, 2023

Yes. Unless exempt or authorized by OFAC, all property and interests in property of persons meeting the definition of the Government of Venezuela (see section 6(d) of E.O. 13884​ of August 5, 2019) that are in, or come within, the United States or the possession or control of a United States person are blocked, pursuant to E.O. 13884. The term “Government of Venezuela,” as defined in E.O. 13884, includes the state and Government of Venezuela, any political subdivision, agency, or instrumentality thereof, including the Central Bank of Venezuela and Petroleos de Venezuela, S.A. (PdVSA), any person owned or controlled, directly or indirectly, by the foregoing, and any person who has acted or purported to act directly or indirectly for or on behalf of, any of the foregoing, including as a member of the Maduro regime.

OFAC has issued several General Licenses (GLs) that provide authorization for categories of persons blocked by E.O. 13884. GL 34A authorizes transactions with certain Government of Venezuela individuals, including United States citizens; permanent resident aliens of the United States; individuals who have a valid U.S. immigrant or nonimmigrant visa, other than individuals in the United States as part of Venezuela’s mission to the United Nations; former employees and contractors of the Government of Venezuela; and current employees and contractors of the Government of Venezuela who provide health or education services in Venezuela, including at hospitals, schools, and universities. In addition, GL 22 authorizes certain transactions related to Venezuela’s mission to the United Nations, and GL 31B provides authorization related to the IV Venezuelan National Assembly seated on January 5, 2016 (“IV National Assembly”). Please see FAQ 679 regarding the scope of GL 31B. Without authorization from OFAC, U.S. persons are generally prohibited from engaging in transactions with the Government of Venezuela, or persons in which the Government of Venezuela owns, directly or indirectly, a 50 percent or greater interest. U.S. persons are not prohibited from engaging in transactions involving the country or people of Venezuela, provided blocked persons or any conduct prohibited by any other Executive order imposing sanctions measures related to the situation in Venezuela, are not involved.

Please note that persons meeting the definition of Government of Venezuela and persons that are owned, directly or indirectly, 50 percent or more by the Government of Venezuela are blocked pursuant to E.O. 13884, regardless of whether the person appears on the Specially Designated Nationals and Blocked Persons list (SDN List), unless exempt or authorized by OFAC.

As a general matter, OFAC expects financial institutions to conduct due diligence on their own direct customers (including, for example, their ownership structure) to confirm that those customers are not persons whose property and interests in property are blocked. For other types of transactions where a financial institution is acting solely as an intermediary and fails to block transactions involving a sanctions target, OFAC will consider the totality of the circumstances surrounding the bank’s processing of the transaction to determine what, if any, regulatory response is appropriate.

Date Updated: January 09, 2023

The United States stands with the Venezuelan people and the IV National Assembly in opposition to the Maduro regime. On January 09, 2023, OFAC issued Venezuela-related General License 31B authorizing all transactions involving the IV National Assembly, its Delegated Commission, any entity established by, or under the direction of, the IV National Assembly to exercise its mandate (“IV National Assembly Entity”), or involving any person appointed or designated by, or whose appointment or designation is retained by, the IV National Assembly, its Delegated Commission, or a IV National Assembly Entity, to act on behalf of the Government of Venezuela, including their respective members and staff, that are otherwise prohibited by E.O. 13884. The authorization also covers transactions prohibited by E.O. 13850, as amended, with respect to any person appointed or designated by, or whose appointment or designation is retained by, the IV National Assembly, its Delegated Commission, or a IV National Assembly Entity to the board of directors (including any ad hoc board of directors) or as an executive officer of a Government of Venezuela entity (including entities owned or controlled, directly or indirectly, by the Government of Venezuela). 

Effective January 09, 2023, General License 31B replaced and superseded General License 31A in its entirety.

Date Updated: January 09, 2023

U.S. persons are generally prohibited from engaging in transactions or dealings with persons named on OFAC’s SDN List, including dealing with an SDN in the context of efforts to restructure Venezuelan and Petroleos de Venezuela, S.A. (PdVSA) debt.  Provided there is no SDN involvement, Venezuela-related General License 3 authorizes U.S. persons to engage in all transactions related to bonds specified in the Annex to General License 3, including participating in negotiations regarding such bonds. General License 3 does not authorize any transaction by a U.S. person or within the United States that involves the creation or subsequent dealing in new debt of PdVSA or debt otherwise of the Government of Venezuela with a maturity of greater than 90 days or 30 days, respectively, absent a license from OFAC.  OFAC would consider license applications involving any such new debt or equity on a case-by-case basis, and base licensing determinations on the facts and circumstances of the particular application.  As stated in FAQ 522, the United States government would consider using licensing authority to allow U.S. persons to deal in new debt of the Government of Venezuela approved by the democratically elected IV Venezuelan National Assembly seated on January 5, 2016.

Date Updated: January 09, 2023

In the Lima Declaration of August 8, 2017, 12 countries across the Americas refused to recognize the Constituent Assembly or the laws it adopts because of its illegitimate nature, while at the same time fully backing the democratically elected IV Venezuelan National Assembly seated on January 5, 2016 (“IV National Assembly”). We stand in solidarity with our friends and allies in the region. If the democratically elected IV National Assembly approved a new debt issuance by the Government of Venezuela that Executive Order (E.O.) 13808 would prohibit U.S. persons from dealing in, the United States would consider using licensing authority to allow U.S. persons to deal in the issuance.

Date Updated: January 09, 2023

For the purposes of the determination of May 8, 2022 made pursuant to E.O. 14071, OFAC anticipates publishing regulations defining these terms to include the following:

• “Accounting services” – includes services related to the measurement, processing, and evaluation of financial data about economic entities.  Please note that OFAC has issued General License 35 to authorize certain transactions ordinarily incident and necessary to the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of credit rating or auditing services to any person located in the Russian Federation through 12:01 a.m. eastern daylight time, August 20, 2022.  See FAQ 1035.
• “Trust and corporate formation services” – includes services related to assisting persons in forming or structuring legal persons, such as trusts and corporations; acting or arranging for other persons to act as directors, secretaries, administrative trustees, trust fiduciaries, registered agents, or nominee shareholders of legal persons; providing a registered office, business address, correspondence address, or administrative address for legal persons; and providing administrative services for trusts.  Please note that all of these activities are common activities of trust and corporate service providers (TCSPs), although they may be provided by other persons.
• “Management consulting services” – includes services related to strategic business advice; organizational and systems planning, evaluation, and selection; development or evaluation of marketing programs or implementation; mergers, acquisitions, and organizational structure; staff augmentation and human resources policies and practices; and brand management.

This determination excludes from the scope of the aforementioned services:  (1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a United States person; and (2) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person.

For the purposes of the prohibitions set forth in in the determination of May 8, 2022 made pursuant to E.O. 14071, OFAC anticipates publishing regulations defining the term “person located in the Russian Federation” as set forth in FAQ 1058.  For the purposes of the exclusion set forth in the determination of May 8, 2022 made pursuant to E.O. 14071, OFAC anticipates publishing regulations defining the term “Russian person” to mean an individual who is a citizen or national of the Russian Federation, or an entity organized under the laws of the Russian Federation.

Date Updated: September 15, 2022

Yes.  On May 8, 2022, OFAC designated Agropromyshlennyi Kompleks Voronezhskii OOO, Anninskii Elevator OOO, and Azovskaya Zernovaya Kompaniya OOO pursuant to Executive Order (E.O.) 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Joint Stock Company Moscow Industrial Bank (MIB), which was also designated on May 8, 2022 pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy.  Russia-related General License (GL) 6B authorizes, among other activities, certain transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), that are related to the sale, or transport of agricultural commodities, which includes transactions ordinarily incident and necessary to the exportation or reexportation of agricultural commodities to, from, or transiting the Russian Federation.  For additional information, please see the text of GL 6B.

For further information on relevant authorizations, exemptions, and public guidance, please review OFAC’s Fact Sheets, “Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine ” and “Russia Sanctions and Agricultural Trade”.

Date Updated: July 14, 2022

Gold-related transactions involving the Russian Federation may be sanctionable under E.O. 14024 or other Russia-related sanctions authorities.  For example, E.O. 14024 authorizes sanctions against:

• Persons determined to be responsible for or complicit in, or to have directly or indirectly engaged or attempted to engage in, deceptive or structured transactions or dealings to circumvent U.S. sanctions, including through the use of assets such as gold or other precious metals;  
• Persons determined to operate or to have operated in the financial services sector of the Russian Federation economy, which could include those engaging in gold-related transactions involving the Russian Federation; and 
• Persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, persons blocked under E.O. 14024.  This could include transactions in gold or other precious metals that involve such blocked persons.

In addition, gold-related transactions involving Russia or the Russian Federation may be prohibited under E.O. 14024 or other Russia-related sanctions authorities.  For example:

• The determination of June 28, 2022 issued pursuant to E.O. 14068, “Prohibitions Related to Imports of Gold of Russian Federation Origin,” prohibits the importation into the United States of certain gold of Russian Federation origin (see FAQ 1070).
• U.S. persons, including gold dealers, distributors, wholesalers, buyers, individual traders, refineries, and financial institutions, are generally prohibited from engaging in or facilitating prohibited transactions, including gold-related transactions, in which blocked persons have an interest. 
• U.S. persons are prohibited from engaging in any transaction — including gold-related transactions — involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, pursuant to Directive 4 under E.O. 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation (Russia-related Sovereign Transactions Directive).  Please see FAQ 998.
• U.S. financial institutions are also generally prohibited from processing transactions, including gold-related transactions, involving foreign financial institutions that are determined to be subject to the prohibitions of Directive 2 under Executive Order 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive).  Please see FAQ 967 and FAQ 969.
• Non-U.S. persons are prohibited from causing or conspiring to cause U.S. persons to violate U.S. sanctions, as well as engaging in conduct that evades or avoids a violation of OFAC sanctions.  

Sanctioned Russian persons are known to employ a wide variety of measures in their efforts to evade U.S. and international sanctions.  As such, U.S. persons, wherever located, including persons that process or facilitate gold-related transactions, must be vigilant against attempts to circumvent OFAC regulations and must take risk-based steps to ensure they do not engage in prohibited transactions. 

Violations of OFAC regulations may result in criminal or civil penalties.  OFAC is closely monitoring any efforts to circumvent or violate Russia-related sanctions, including through the use of gold or other precious metals, and is committed to using its authorities to act against sanctions evaders, and promote compliance.
 

Date Updated: June 28, 2022

No.  E.O. 14065 targets the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”).  In determining whether a location is within the regions subject to sanctions, U.S. persons may reasonably rely on vetted information from reliable third parties, such as postal codes and maps.

U.S. persons engaging in activity that does not involve the Covered Regions are not subject to the prohibitions in E.O. 14065.  Please see FAQ 1006 for what prohibitions apply to the Covered Regions. 

Date Updated: May 05, 2022

For purposes of section 10(a)(2)(A) of SSIDES and § 589.201(a)(6)(vii)(B)(1) of the URSR, OFAC will interpret the phrase “subject to sanctions imposed by the United States with respect to the Russian Federation” to be persons subject to sanctions under SSIDES, as amended, the Ukraine Freedom Support Act (UFSA), as amended, provisions of CAATSA with respect to the Russian Federation, and any covered Executive order as defined in § 589.305 and section 10(f)(1) of SSIDES.  Section 10(f)(1) of SSIDES and § 589.305 define the term “covered executive order” to mean any of the following:   Executive Order (E.O.) 13660, E.O. 13661, E.O. 13662, E.O. 13685, E.O. 13694, relating to the Russian Federation, or E.O. 13757, relating to the Russian Federation.  Persons “subject to sanctions imposed by the United States with respect to the Russian Federation” includes persons who are listed on the SDN List, SSI List, or NS-MBS List pursuant to the authorities listed above, and associated persons subject to sanctions pursuant to OFAC’s 50 percent rule.

Date Updated: April 29, 2022

“foreign person” – As stated in § 589.317 of the Ukraine-/Russia-Related Sanctions Regulations (URSR), the term foreign person for purposes of the SSIDES section 10 provisions in §§ 589.201(a)(6) and 589.413 means any citizen or national of a foreign state (including any such individual who is also a citizen or national of the United States), or any entity not organized solely under the laws of the United States or existing solely in the United States, but does not include a foreign state.  This definition is consistent with section 10(f)(2) of SSIDES.

“knowingly” – section 589.322 states that the term knowingly, with respect to conduct, a circumstance, or a result, means that a person has actual knowledge, or should have known, of the conduct, the circumstance, or the result.  This definition is consistent with section 221(4) of CAATSA.

“materially violate” – For purposes of section 10(a)(1) of SSIDES, OFAC will interpret the term “materially violate” to refer to an “egregious” violation.  A determination about whether a violation is egregious will be based on an analysis of the applicable General Factors as described in OFAC’s Economic Sanctions Enforcement Guidelines, located in subsection (B)(1), section V of Appendix A to 31 C.F.R. part 501.

“facilitate[ion] . . . for or on behalf of” – For purposes of section 10(a)(2) of SSIDES, facilitating a significant transaction for or on behalf of a person will be interpreted to mean providing assistance for a transaction from which the person in question derives a particular benefit of any kind (as opposed to a generalized benefit conferred upon undifferentiated persons in aggregate).  Assistance may include the provision or transmission of currency, financial instruments, securities, or any other value; purchasing, selling, transporting, swapping, brokering, financing, approving, or guaranteeing; the provision of other services of any kind; the provision of personnel; or the provision of software, technology, or goods of any kind.

“significant transaction” – section 589.413 states that for purposes of the SSIDES prohibitions in § 589.201(a)(6)(vii), the Secretary of the Treasury or the Secretary’s designee will consider the totality of the facts and circumstances when determining whether transactions are “significant.”  As a general matter, some or all of the following factors may be considered: (1) the size, number, and frequency of the transaction(s); (2) the nature of the transaction(s); (3) the level of awareness of management and whether the transaction(s) are part of a pattern of conduct; (4) the nexus between the transaction(s) and the person subject to sanctions imposed by the United States with respect to the Russian Federation, as defined in SSIDES, or any child, spouse, parent, or sibling of such an individual; (5) the impact of the transaction(s) on the objectives of the Ukraine Freedom Support Act, SSIDES, CAATSA, Executive Order (E.O.) 13660, E.O. 13661, E.O. 13662, E.O. 13685, or any other Executive order issued pursuant to the national emergency declared in E.O. 13660; (6) whether the transaction(s) involve deceptive practices; and (7) such other factors that the Secretary of the Treasury or the Secretary’s designee deems relevant on a case-by-case basis.  

Furthermore, § 589.413(i) states a transaction is not significant if U.S. persons would not require specific licenses from OFAC to participate in it.  A transaction in which the person subject to sanctions is identified on the Sectoral Sanctions Identifications (SSI) List or the Non-SDN Menu-Based Sanctions (NS-MBS) List will only be potentially considered significant if:  1) the transaction involves deceptive practices (i.e., attempts to obscure or conceal the actual parties or true nature of the transaction(s), or to evade sanctions); and 2) such person is “subject to sanctions imposed by the United States with respect to the Russian Federation” or a child, spouse, parent, or sibling of such an individual, as described in § 589.413(d)(1) (see also FAQ 546).  

A transaction involving an entity solely on the SSI List or NS-MBS List is not automatically significant simply because a U.S. person would require a specific license from OFAC to participate in it and it involves deceptive practices.  In all cases, the totality of the circumstances, including the other factors listed above, will shape the final determination of significance.

“Deceptive or structured transaction” – the term structured, with respect to a transaction, has the meaning given the term “structure” in 31 CFR 1010.100 (xx) (or any corresponding similar regulation or ruling).  See 31 C.F.R. § 589.336.

Structured transactions are a type of deceptive transaction.  A “deceptive transaction” is one that involves deceptive practices.  As described in 31 C.F.R. § 589.413(f), “deceptive practices” are attempts to obscure or conceal the actual parties or true nature of a transaction, or to evade sanctions. 

Date Updated: April 29, 2022

If, pursuant to § 589.209 of the URSR, Treasury decides to impose strict condition(s) on maintaining U.S. correspondent accounts or U.S. payable-through accounts for an FFI, or decides to prohibit the opening or maintaining of U.S. correspondent accounts or U.S. payable-through accounts for an FFI, Treasury will add the name of the FFI to the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List) on OFAC’s website and publish the name of the FFI in the Federal Register along with the applicable prohibition or strict condition(s).  The CAPTA List will be included in the Consolidated Sanctions List Data Files and will be available for download in all Consolidated Sanctions List data file formats. 

Date Updated: April 29, 2022

“Significant transaction” and “significant financial transaction”– section 589.413 of the URSR states that for purposes of the UFSA prohibitions in § 589.209, the Secretary of the Treasury will consider the totality of the facts and circumstances when determining whether transactions or financial transactions are “significant.”  As a general matter, some or all of the following factors may be considered:  (1) the size, number, and frequency of the transaction(s); (2) the nature of the transaction(s); (3) the level of awareness of management and whether the transaction(s) are part of a pattern of conduct; (4) the nexus between the transaction(s) and a person subject to sanctions imposed by the United States with respect to the Russian Federation as described in § 589.413(d)(2)–(3); (5) the impact of the transaction(s) on statutory objectives; (6) whether the transaction(s) involve deceptive practices; and (7) such other factors that the Secretary of the Treasury deems relevant on a case-by-case basis.  
For purposes of section 5 of UFSA as implemented by § 589.209, a transaction is not significant if U.S. persons would not require a specific license from OFAC to participate in it.  
For purposes of § 589.209(b), a transaction in which the person subject to sanctions is identified on the Sectoral Sanctions Identifications (SSI) List or the Non-SDN Menu-Based Sanctions (NS-MBS) List will only be potentially considered significant if:  1) the transaction involves deceptive practices (i.e., attempts to obscure or conceal the actual parties or true nature of the transaction(s), or to evade sanctions); and 2) such person is subject to sanctions pursuant to section of UFSA, as described in § 589.413(d)(2).
OFAC will generally interpret the term “financial transaction” broadly to encompass any transfer of value involving a financial institution.  For example, the following is a non-exhaustive list of activities that OFAC would consider to be a “financial transaction”:

• The receipt or origination of wire transfers;
• The acceptance of commercial paper (both retail and wholesale), and the clearance of such paper (including checks and similar drafts);
• The receipt or origination of ACH or ATM transactions;
• The holding of nostro, vostro, or loro accounts;
• The provision of trade finance or letter of credit services;
• The provision of guarantees or similar instruments;
• The provision of investment products or instruments or participation in investments; and
• Any other transactions for or on behalf of, directly or indirectly, a person serving as a correspondent, respondent, or beneficiary.

“Facilitated” – For purposes of implementing section 5 of UFSA, OFAC will generally interpret the term “facilitated” broadly.  “Facilitated” refers to the provision of assistance for certain efforts, activities, or transactions, including the provision of currency, financial instruments, securities, or any other transmission of value; purchasing; selling; transporting; swapping; brokering; financing; approving; guaranteeing; the provision of other services of any kind; the provision of personnel; or the provision of software, technology, or goods of any kind.

Date Updated: April 29, 2022

Section 226 of CAATSA amended section 5 of UFSA to make the sanctions in that section, which were previously discretionary, mandatory.  This section is implemented in § 589.209 of the URSR.  Under § 589.209, FFIs face sanctions if the Secretary of the Treasury determines that they knowingly engage in significant transactions involving certain defense- and energy-related activities or knowingly facilitate significant financial transactions on behalf of any Russian person added to OFAC’s SDN List pursuant to UFSA, Executive Order (E.O.) 13660, E.O. 13661, E.O. 13662, E.O. 13865, or any other E.O. addressing the crisis in Ukraine.  FFIs will not be subject to sanctions under § 589.209 solely on the basis of knowingly facilitating significant financial transactions on behalf of persons listed on OFAC’s Sectoral Sanctions Identification List pursuant to § 589.202, 589.203, 589.204, or 589.205, or any earlier version of Directives 1-4 of E.O. 13662.

Unless the Secretary of State makes a determination that it is not in the national interest of the United States to do so, the Secretary of the Treasury shall prohibit the opening and prohibit or impose strict conditions on the maintaining in the United States of correspondent accounts or payable-through accounts for any FFI that the Secretary of the Treasury, in consultation with the Secretary of State, determines has engaged in sanctionable activity.

Date Updated: April 29, 2022

The term "shale projects," as defined in § 589.334 of the URSR, includes projects that have the potential to produce oil from resources located in shale formations as well as projects that have the potential to produce oil from resources located in fine-grained sedimentary rock formations including shale, limestone, dolomites, sandstones, and clay. 

Date Updated: April 29, 2022

Yes, GL 15L authorizes U.S. persons to receive regularly scheduled payments of principal and interest from GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) only to the extent such transactions are ordinarily incident and necessary to the wind down of transactions involving GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) through 12:01 a.m. eastern daylight time, May 25, 2022, and provided the other terms and conditions of GL 15L are met.  As a general matter, GL 15L also would authorize U.S. persons to receive accelerated payments or voluntary prepayments from GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) so long as such accelerated payments or voluntary prepayments were ordinarily incident and necessary to the wind down of transactions as authorized by GL 15L.  However, GL 15K does not authorize U.S. persons to send accelerated payments or voluntary prepayments to GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest).  If you are unsure about whether GL 15L authorizes such accelerated payments or voluntary prepayments, you may contact OFAC.

Date Updated: April 25, 2022

GL 15L authorizes transactions and activities that are ordinarily incident and necessary to the wind down of transactions involving GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest), including exports.  Any exports to GAZ Group must be consistent with GL 15L and must also be consistent with the requirements of other U.S. federal agencies.  After the expiration of GL 15L, unless exempt or authorized by OFAC, U.S. persons will be prohibited from engaging in any transactions (including those related to wind down and exports) involving GAZ Group, or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, and must block property or interests in property of such persons that are in, or come within, the United States, or the possession or control of a U.S. person.

Date Updated: April 25, 2022

No.  U.S. persons may engage in activities authorized by GL 15L that occur on or after May 22, 2018, except for activities involving blocked persons other than GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) without making associated payments into a blocked account.  Similarly, foreign persons may engage in activities that would be authorized by GL 15L if engaged in by a U.S. person without making associated payments into a blocked account.

Date Updated: April 25, 2022

As described in FAQs 542, 545, 574, and 579, a transaction will not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES, as amended by section 228 of CAATSA, and section 5 of UFSA, 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

GL 15L superseded GL 15K on April 25, 2022.  While GL 15K authorized certain transactions and activities that were ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements involving GAZ Group, or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, and that were in effect prior to April 6, 2018, GL 15L only authorizes certain transactions and activities that are ordinarily incident and necessary to the wind down of transactions involving GAZ Group and any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest through 12:01 a.m. eastern daylight time, May 25, 2022.

All funds blocked prior to 12:01 a.m. eastern daylight time, May 22, 2018, remain blocked.  Unlike its predecessors, this general license no longer authorizes the use of these blocked funds for the activities it authorizes.  In addition, U.S. persons have not been required to block transactions authorized by GL 15L or its predecessors that occurred on or after May 22, 2018; however, transactions involving blocked persons other than GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, must be blocked.  For information regarding the relationship between GL 15L and foreign persons, please see FAQs 589 and 590.

After the expiration of GL 15L, unless exempt or authorized by OFAC, U.S. persons will be prohibited from engaging in transactions involving GAZ Group, or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, and must block property or interests in property of such persons that are in, or come within, the United States, or the possession or control of a U.S. person.

Date Updated: April 25, 2022

No.  Until 12:01 a.m. eastern daylight time, May 25, 2022, GL 13R authorizes certain divestment and transfer activities related to debt, equity, or other holdings in GAZ Group, or in entities in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, that were issued by GAZ Auto Plant (“Other Issuer Holdings”), subject to certain conditions and exceptions.  It does not authorize U.S. persons to sell debt, equity, or other holdings to; to purchase or invest in debt, equity, or other holdings in; or to facilitate such transactions with, directly or indirectly, GAZ Group or any other blocked person, other than transactions and activities involving GAZ Group, or entities in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest that are ordinarily incident and necessary to the divestment or transfer of debt, equity, or other holdings in these entities.

GL 13R superseded GL 13Q on April 25, 2022.  After the expiration of GL 13Q, U.S. persons will be prohibited from engaging in any divestment or transfer activities on behalf of U.S. persons or non-U.S. persons related to debt, equity, or other holdings that previously were authorized by GL 13Q.

Date Updated: April 25, 2022

Until 12:01 a.m. eastern daylight time, May 25, 2022, General License (GL) 13R authorizes certain divestment and transfer activities related to debt, equity, or other holdings in GAZ Group, or in entities in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, that were issued by GAZ Auto Plant (“Other Issuer Holdings”), subject to certain conditions and exceptions.  Specifically, GL 13R authorizes U.S. persons to divest or transfer to a non-U.S. person, or to facilitate the transfer by a non-U.S. person to another non-U.S. person, debt, equity, or other holdings in GAZ Group or Other Issuer Holdings as described in GL13R.  However, such divestment, transfer, or facilitation must not result in U.S. persons selling debt, equity, or other holdings to; purchasing or investing in debt, equity, or other holdings in; or facilitating such transactions with, directly or indirectly, any blocked person, including GAZ Group, other than transactions and activities involving GAZ Group, or entities in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest that are ordinarily incident and necessary to the divestment or transfer of debt, equity, or other holdings in the entities identified in GL 13R.  Please see GL 13R for further details.

GL 13R superseded GL 13Q on April 25, 2022.  After the expiration of GL 13R, U.S. persons will be prohibited from engaging in any divestment or transfer activities on behalf of U.S. persons or non-U.S. persons related to debt, equity, or other holdings that previously were authorized in GL 13R.

Date Updated: April 25, 2022

General License (GL) 9A authorizes U.S. persons, until 12:01 a.m. eastern daylight time May 25, 2022, to engage in transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, that are ordinarily incident and necessary to dealings in debt or equity issued prior to February 24, 2022 of one or more of the following entities (“covered debt or equity”), provided that any divestment or transfer of, or facilitation of divestment or transfer of, covered debt or equity must be to a non-U.S. person:

• State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB);
• Public Joint Stock Company Bank Financial Corporation Otkritie; 
• Sovcombank Open Joint Stock Company;
• Public Joint Stock Company Sberbank of Russia;
• VTB Bank Public Joint Stock Company;
• Any entity owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one of the above entities.

This authorization includes the facilitation, clearing, and settling of transactions ordinarily incident and necessary to divest covered debt or equity to a non-U.S. person, including on behalf of U.S. persons.  Also, as part of a divestment transaction to a non-U.S. person, U.S. persons may engage in purchases of or investment in covered debt or equity if ordinarily incident and necessary to buy to cover a short position in such holdings.

To allow the closing of trades initiated before February 24, 2022, paragraph (b) of GL 9A authorizes all transactions that are ordinarily incident and necessary to facilitating, clearing, and settling trades of covered debt or equity through 12:01 a.m. eastern daylight time May 25, 2022, provided such trades were placed prior to 4:00 p.m. eastern standard time on February 24, 2022, including debits to accounts on the books of U.S. financial institutions of certain blocked entities.  

GL 9A also authorizes U.S. persons to receive interest, dividend, or maturity payments on debt or equity of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation through 12:01 a.m. eastern daylight time on May 25, 2022.  After May 25, 2022, U.S. persons would require a specific license to continue to receive such payments.  

Certain transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, are not authorized by GL 9A.  Please see GL 9A for additional details.  Please also see GL 10A with respect to authorizations related to certain derivative contracts. 

For purposes of assessing whether certain transactions are authorized under GL 9A or GL 10A, U.S. persons—including financial institutions, registered broker-dealers in securities, securities exchanges, and other market intermediaries and participants—may rely upon the information available to them in the ordinary course of business, including reasonable reliance on information about the underlying transaction provided by the parties thereto.  However, U.S. persons should also exercise caution in engaging in foreign exchange transactions on the Moscow Exchange given the current heightened risk that the Central Bank of the Russia Federation could be a counterparty to such transactions (see FAQ 1002). 

Date Updated: March 02, 2022

On February 22, 2022, the Office of Foreign Assets Control (OFAC) designated specified Russian financial institutions pursuant to E.O. 14024 , including the State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), Promsvyazbank Public Joint Stock Company, and many of their subsidiaries.  OFAC designated additional Russian financial institutions on February 24, 2022, including VTB Bank Public Joint Stock Company, Public Joint Stock Company Bank Financial Corporation Otkritie (Otkritie), Sovcombank Open Joint Stock Company (Sovcombank), Joint Stock Commercial Bank Novikombank, and many of these financial institutions’ subsidiaries.  As a result, all property and interests in property of these entities in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked and must be reported to OFAC.  In addition, all property and interests in property of any entity that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.  Accordingly, U.S. persons, including U.S. financial institutions, are prohibited from transacting with these entities unless exempt or authorized by OFAC.  

• OFAC issued several Russia-related general licenses (GLs) authorizing transactions involving specified blocked Russian financial institutions, including:
• GL 2 : authorizing certain transactions involving VEB related to servicing obligations of certain Russian sovereign debt;
• GL  3: authorizing the wind down of certain transactions involving VEB until 12:01 a.m. eastern daylight time, March 24, 2022;
• GL  11: authorizing the wind down of certain transactions involving VTB Bank Public Joint Stock Company, Otkritie, and Sovcombank until 12:01 a.m. eastern daylight time, March 26, 2022; and
• GL  12: authorizing the rejection (rather than blocking) of certain transactions involving VTB Bank Public Joint Stock Company, Otkritie, and Sovcombank until 12:01 a.m. eastern daylight time, March 26, 2022.

Note that these GLs do not authorize certain activities with all blocked Russian financial institutions; nor does each GL authorize certain activities with the same group of blocked Russian financial institutions.  For example, the GLs listed above do not authorize any transactions involving Promsvyazbank Public Joint Stock Company or Joint Stock Commercial Bank Novikombank, and GLs 2 and 3 relate only to VEB.  

Other GLs that may be applicable to one or more of the Russian financial institutions blocked in February 2022 include:

• GL  5: authorizing transactions related to the official business of certain international organizations and other entities;
• GL  6: authorizing certain transactions related to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates, or the prevention, diagnosis, or treatment of COVID-19;
• GL  7: authorizing overflight payments, emergency landings, and air ambulance services;
• GL  8A: authorizing transactions related to energy;
• GL  9A: authorizing transactions related to dealings in certain debt and equity until 12:01 a.m. eastern daylight time, May 25, 2022; and
• GL  10A: authorizing certain transactions related to derivative contracts until 12:01 a.m. eastern daylight time, May 25, 2022. 

Please consult each GL for further information regarding its scope.  

On March 1, 2022, OFAC issued the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), which incorporate GL 5 in section 587.510 of the RuHSR.

Additionally, consistent with section 9 of E.O. 14024, transactions for the conduct of the official business of the Federal Government or the United Nations (including its specialized agencies, programs, funds, and related organizations) by employees, grantees, and contractors thereof are exempt from the sanctions prohibitions of E.O. 14024.

Date Updated: March 02, 2022

Directive 1 under E.O. 14024 of April 15, 2021 imposed prohibitions on participation in the primary market for ruble or non-ruble denominated bonds issued by, or the lending of ruble or non-ruble denominated funds to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.  The Russia-related Sovereign Debt Directive replaces and supersedes Directive 1 under E.O. 14024 of April 15, 2021.  It expands upon the existing prohibitions to also prohibit, as of March 1, 2022 , participation in the secondary market for ruble or non-ruble denominated bonds issued by these entities after March 1, 2022.  Please see FAQ 888 for additional details on the effective dates of these prohibitions.

The Russia-related Sovereign Debt Directive also includes technical revisions to the definition of “U.S. financial institution” to expand the definition.

Independent of the Russia-related Sovereign Debt Directive, OFAC has imposed prohibitions on certain Russia-related entities subject to the Russia-related Sovereign Debt Directive, pursuant to Russia-related directives under E.O. 13883 and E.O. 14024.

Date Updated: March 02, 2022

The prohibitions announced by the State Department on August 20, 2021 related to U.S. bank loans have the same scope as those imposed by OFAC in August 2019 under the CBW Act Directive.  Please see FAQs 675–678 for additional information.

Independent of the CBW Act Directive, OFAC has imposed prohibitions on certain Russia-related sovereign entities subject to the CBW Act Directive, pursuant to Russia-related directives under Executive Order (E.O.) 14024 (see FAQ 1000).

Date Updated: March 02, 2022

Even prior to June 14, 2021, “U.S. banks” were prohibited from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign (including the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation), and from lending non-ruble denominated funds to the Russian sovereign pursuant to the Russia-related Directive under Executive Order 13883 (“CBW Act Directive”), which was issued on August 2, 2019 and went into effect on August 26, 2019.  However, the CBW Act Directive does not prohibit “U.S. banks” (as defined in the CBW Act Directive) from participating in the primary market for ruble denominated bonds issued by the Russian sovereign, or the lending of ruble denominated funds to the Russian sovereign.

Pursuant to Directive 1A under (E.O.) 14024 , “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), after June 14, 2021, U.S. financial institutions (as defined in the Russia-related Sovereign Debt Directive) are prohibited from participating in the primary market for ruble or non-ruble denominated bonds issued by, or the lending of ruble or non-ruble denominated funds to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, unless otherwise authorized by OFAC or exempt.  Pursuant to the Russia-related Sovereign Debt Directive, as of March 1, 2022, U.S. financial institutions are also prohibited from participating in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by these entities. 

Note that the prohibitions found in the CBW Act Directive remain in effect and are separate from the prohibitions of the Russia-related Sovereign Debt Directive, or other directives under E.O. 14024.  For more information on the CBW Act Directive, please see FAQs 673 - 678.

Date Updated: March 02, 2022

Pursuant to the Russia-related Sovereign Debt Directive, the following activities by a U.S. financial institution are prohibited:

1. As of June 14, 2021, participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; 
2. As of June 14, 2021, lending ruble or non-ruble denominated funds to the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; and
3. As of March 1, 2022, participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.

Further, except to the extent otherwise provided by law or unless authorized by OFAC or exempt, the following are also prohibited pursuant to the Russia-related Sovereign Debt Directive:  (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the Russia-related Sovereign Debt Directive; and (2) any conspiracy formed to violate any of the prohibitions of the Russia-related Sovereign Debt Directive. 

Independent of the Russia-related Sovereign Debt Directive, OFAC has imposed prohibitions on certain Russia-related entities subject to the Russia-related Sovereign Debt Directive, pursuant to Russia-related directives under Executive Order (E.O.) 13883 and E.O. 14024.

Date Updated: March 02, 2022

No, the CBW Act Directive does not prohibit U.S. banks from participating in the secondary market for Russian sovereign debt.  However, independent of the CBW Act Directive, OFAC has imposed prohibitions on certain Russia-related sovereign entities subject to the CBW Act Directive, pursuant to Russia-related directives under Executive Order (E.O.) 14024 (see FAQ 1000).

Date Updated: March 02, 2022

The CBW Act Directive defines the term “U.S. banks.”  This definition is consistent with section 4(c) of Executive Order (E.O.) 13883, and with the definition of “U.S. financial institution” at 31 CFR § 544.311.  The CBW Act Directive defines the term “Russian sovereign” as any ministry, agency, or sovereign fund of the Russian Federation, including the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance of the Russian Federation.   This term does not include state-owned enterprises of the Russian Federation.

Independent of the CBW Act Directive, OFAC has imposed prohibitions on certain Russia-related sovereign entities subject to the CBW Act Directive, pursuant to Russia-related directives under E.O. 14024 (see FAQ 1000).

Date Updated: March 02, 2022

Pursuant to Executive Order (E.O.). 13883, 31 CFR § 544.802, and the CBW Act, on August 2, 2019, OFAC issued a Russia-Related Directive (the “CBW Act Directive”), which prohibits U.S. banks from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign and also prohibits U.S. banks from lending non-ruble denominated funds to the Russian sovereign.  The prohibitions under the CBW Act Directive do not apply to bonds or loans denominated in rubles.  The prohibitions in the CBW Act Directive only apply to “U.S. banks,” as that term is defined in the CBW Act Directive and consistent with section 4(c) of E.O. 13883 and consistent with the definition of U.S. financial institution at 31 CFR § 544.311.  The CBW Act Directive includes a definition of the term “Russian sovereign.”  The CBW Act Directive is effective as of August 26, 2019.

Independent of the CBW Act Directive, OFAC has imposed additional prohibitions on certain Russia-related sovereign entities subject to the CBW Act Directive, pursuant to Russia-related directives under E.O. 14024 (see FAQ 1000).

Date Updated: March 02, 2022

Yes, cash shipments to Afghanistan may be authorized under General Licenses (GL) 14, GL 18, GL 19, or GL 20  provided that they are ordinarily incident and necessary to effectuate the activities authorized by the GLs.  

As with all OFAC GLs, GLs 14, 18, 19, and 20 are “self-executing,” meaning that persons who determine that such activities are ordinarily incident and necessary to their authorized activities within the scope of the GLs may proceed without further assurances from OFAC.

Date Updated: February 25, 2022

Yes.  Transactions that are ordinarily incident and necessary to give effect to the activities authorized in General Licenses (GL) 14, GL 15, GL 16, GL 17, GL 18, GL 19, or GL 20, including clearing, settlement, and transfers through, to, or otherwise involving privately owned and state-owned Afghan depository institutions, are authorized pursuant to these GLs. 

In addition, foreign financial institutions may engage in or facilitate transactions that would be authorized for U.S. persons under GLs 14, 15, 16, 17, 18, 19, or 20 without exposure to sanctions under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended.

Date Updated: February 25, 2022

Yes. Support to municipal water systems by NGOs for projects that directly benefit the Afghan people or otherwise relieve human suffering that would otherwise be prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, because of transactions with the Taliban and/or Haqqani Network would be covered by General Licenses (GLs) 14 and 19. GL 18 authorizes all transactions and activities with the Taliban and/or Haqqani Network otherwise prohibited under the GTSR or FTOSR that are for the conduct of the official business of certain IOs. Thus, if support to municipal water systems is part of these IOs’ official business, then it would not be prohibited.

For example, this could include providing technical support to a project related to clean drinking water or making improvements to water systems for the benefit of the Afghan people.

In addition, OFAC has issued Afghanistan-related GL 20, which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the GTSR, the FTOSR, or E.O. 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b). GL 20 therefore also covers support to municipal water systems by NGOs, IOs, or other persons.

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related GLs 14, 18, and 19. Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 18, and 19.

Date Updated: February 25, 2022

Yes.  Even to the extent doing so would involve transacting with the Taliban and/or Haqqani Network, NGOs can make salary support or stipend payments directly to healthcare workers, such as doctors at public hospitals or healthcare workers at community clinics, under General License (GL) 14 and GL 19.  Similarly, even to the extent doing so would involve transacting with the Taliban and/or Haqqani Network, NGOs can make such salary support or stipend payments directly to teachers, including teachers at Afghan public and private schools, under GL 19.  Under GL 18, certain IOs can provide such salary support payments directly to healthcare workers and teachers.  

In addition, OFAC has issued Afghanistan-related GL 20 , which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers salary support or stipend payments directly to teachers, including teachers at Afghan public and private schools, and healthcare workers by NGOs or other persons.   

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related GLs 14, 15, and 19.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 15, and 19.

Date Updated: February 25, 2022

Yes.  Providing support to public hospitals, such as provision of health services, technical support, and institutional deliveries, as well as payments directly to healthcare workers, that would otherwise be prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, because of transactions with the Taliban and/or Haqqani Network are authorized under General Licenses (GLs) 14, 15, and 19. 

In addition, OFAC has issued Afghanistan-related GL 20 , which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the GTSR, the FTOSR, or E.O. 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers support to public hospitals in Afghanistan (e.g., health services, facilities maintenance, and health worker salaries) by NGOs or other persons.   

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related GLs 14, 15, and 19.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 15, and 19.

Date Updated: February 25, 2022

As one example, if a non-governmental organization is providing support directly to Afghan hospitals or healthcare workers but needs to sign a memorandum of understanding that involves the Taliban in order to provide such support directly to the Afghan people, this engagement would be authorized under General Licenses (GLs) 14 and 19.

Other examples of engagement with the Taliban and the Haqqani Network that are authorized under GLs 14 and 19 if they are ordinarily incident and necessary to activities authorized by these GLs include: (i) general coordination on delivery and provision of humanitarian aid or shipments; (ii) administrative issues involving importation of goods; (iii) attendance at donor coordination meetings; (iv) sharing descriptions of projects; (v) coordination with regard to travel or project locations; (vi) participation in technical working groups; and (vii) sharing of office space.

In addition, payments of taxes, fees, or import duties to, or the purchase or receipt of permits, licenses, or public utility services from, the Taliban, the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest, are authorized under GLs 14 and 19, if ordinarily incident and necessary to activities authorized by the GLs.  

In addition, OFAC has issued Afghanistan-related GL 20 , which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers transactions involving the Taliban or the Haqqani Network that are authorized under GLs 14 and 19.  

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related GLs 14 and 19.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14 and 19. 

Date Updated: February 25, 2022

Yes.  Both U.S. and non-U.S. companies can ship food to Afghanistan, and banks can process financial transfers and other transactions associated with food shipments to Afghanistan.

As described in FAQ 930, U.S. sanctions do not specifically prohibit the exportation or reexportation of agricultural commodities, medicine, and medical devices to Afghanistan.

OFAC has also issued Afghanistan-related General License (GL) 15, which authorizes U.S. persons to engage in all transactions that are ordinarily incident and necessary to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts, and components for medical devices, or software updates for medical devices to Afghanistan, as those terms are defined in GL 15, as well as to persons in third countries purchasing specifically for resale to Afghanistan, and that may involve the Taliban, the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest subject to certain conditions.  FAQ 931 provides further guidance that non-U.S. persons may engage in or facilitate transactions that would be authorized for U.S. persons under GL 15.

GL 15 also authorizes U.S. persons to engage in transactions or activities that are ordinarily incident and necessary to authorized exports or reexports, including the processing of financial transactions and related clearing and settlement involving privately-owned and state-owned banks in Afghanistan.  

In addition, OFAC has issued Afghanistan-related GL 20 , which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers shipments of food and agricultural products to Afghanistan and banks’ processing of these transactions.

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorization in Afghanistan-related GL 15.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorization in GL 15. 

Date Updated: February 25, 2022

Yes. GLs 14, 15, 16, 17, 18, 19and 20  help implement recently adopted United Nations Security Council Resolution (UNSCR) 2615 (2021), which authorizes humanitarian assistance and other activities that support basic human needs as those terms are understood by the UN Security Council, as well as the processing and payment of funds, other financial assets or economic resources, and the provision of goods and services necessary to ensure the timely delivery of such assistance or to support such activities.  Specifically, UNSCR 2615 was intended to cover activities contemplated in the United Nations’ Transitional Engagement Framework (TEF) for Afghanistan, such as providing life-saving assistance; sustaining essential services; and preserving social investments and community-level systems essential to meeting basic human needs.

These GLs do not relieve any person from compliance with other U.S. federal laws or requirements of other federal agencies, or from applicable international obligations.

Date Updated: February 25, 2022

No.  U.S. sanctions on the Taliban and the Haqqani Network do not prohibit the movement of funds into or out of Afghanistan, provided that the transactions do not involve blocked individuals or entities, or property in which a blocked person has an interest.  

In addition, OFAC has issued General Licenses (GLs) 14, 15, 16, 17, 18, 19 and 20 under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), and Executive Order (E.O.) 13224, as amended.  For a consolidated list of all relevant General Licenses and FAQs, please see OFAC’s humanitarian Fact Sheet, “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People” (this content was updated on April 13, 2022), that provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. 

U.S. sanctions on the Taliban and the Haqqani Network do not prohibit — and GLs 14, 15, 16, 17, 18, 19, and 20 do not require — any particular method for moving or sending money into or out of Afghanistan.  When selecting a method of payment — including electronic transfer or hand carrying of funds — OFAC urges due diligence tailored to the particular sanctions risks to ensure that payments do not involve individuals or entities identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) or whose property and interests in property are otherwise blocked, unless exempt from regulation or authorized by OFAC.  For more information on OFAC due diligence expectations and compliance programs, please see FAQs 25, 27-31 and A Framework for OFAC Compliance Commitments.

Date Updated: February 25, 2022

A number of members of the Taliban and/or the Haqqani Network are explicitly included on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List).  Persons operating in Afghanistan can use OFAC’s SDN List Search Tool to identify such members of the Taliban or the Haqqani Networks explicitly included on the SDN List, as well as other individuals or entities explicitly subject to U.S. sanctions.  For more information on using OFAC’s SDN List Search Tool and assessing OFAC Name Matches, please see OFAC FAQs 5, 82, 246-253, 287, 369, 467, and 892.  

OFAC would encourage any person operating in Afghanistan to use all information at their disposal when assessing their risk for sanctions exposure.  Supplementing internal due diligence information with an array of open-source material can be an effective compliance practice to aid in identifying risky counterparties involved in any in-country activity.  For more information on OFAC due diligence expectations and compliance programs, please see FAQs 25, 27-31 and A Framework for OFAC Compliance Commitments.

Date Updated: February 25, 2022

No.  In contrast to sanctions programs administered and enforced by OFAC with regard to North Korea, Cuba, Iran, Syria, and the Crimea and so-called Donetsk People’s Republic and Luhansk People’s Republic regions  of Ukraine, there are no comprehensive sanctions on Afghanistan.  Therefore, there are no OFAC-administered sanctions that prohibit the export or reexport of goods or services to Afghanistan, moving or sending money into and out of Afghanistan, or activities in Afghanistan, provided that such transactions or activities do not involve sanctioned individuals, entities, or property in which sanctioned individuals and entities have an interest.

Certain Afghanistan-related individuals and entities are included on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), most notably the Taliban and the Haqqani Network.  The Taliban are designated as a Specially Designated Global Terrorist (SDGT) under Executive Order (E.O.) 13224.  The Haqqani Network is designated as an SDGT under E.O. 13224 and a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and Nationality Act.  Transactions or activities by U.S. persons that involve these entities are generally prohibited.  

In addition, OFAC has issued GLs 14, 15, 16, 17, 18, 19, and 20  under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), and E.O. 13224, as amended.  For a consolidated list of all relevant General Licenses and FAQs, please see OFAC’s humanitarian Fact Sheet, “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People,” (this content was updated on April 13, 2022) that provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. 

Date Updated: February 25, 2022

No.  The Taliban are designated as a Specially Designated Global Terrorist (SDGT) Executive Order (E.O.) 13224, as amended.  The Haqqani Network is designated as an SDGT under E.O. 13224, as amended, and a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and Nationality Act (INA).  These sanctions do not prohibit U.S. persons from exporting or reexporting goods or services (including noncommercial, personal remittances) to Afghanistan, provided that the transactions do not involve sanctioned individuals or entities, or property in which a blocked person has an interest, unless exempt from regulation or authorized by OFAC.  For example, U.S. sanctions do not prohibit the hand-carrying of noncommercial, personal remittances to an individual in Afghanistan or ordinarily resident in Afghanistan, other than a blocked individual.

OFAC has also issued Afghanistan-related General License (GL) 16 to facilitate the transfer of noncommercial, personal remittances to individuals in Afghanistan.  GL 16 authorizes U.S. persons to engage in transactions that are ordinarily incident and necessary to the transfer of noncommercial, personal remittances, including through Afghan depository institutions, and that may involve the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, that are prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or E.O. 13224, as amended.

In addition, OFAC has issued Afghanistan-related GL 20, which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the GTSR, the FTOSR, or E.O. 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers the sending of personal remittances to Afghanistan.

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorization in Afghanistan-related GL 16.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GL 16.  However, GLs 16 and 20 do not authorize any debit to a blocked account of the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, on the books of a U.S. financial institution.  In addition, GLs 16 and 20 do not authorize financial transfers to the Taliban, the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, other than for the purpose of effecting the payment of reasonable and customary taxes, fees, or other duties as described in the respective GLs.  Transactions that are ordinarily incident and necessary to give effect to the activities authorized in GLs 16 and 20, including clearing, settlement, and transfers through, to, or otherwise involving privately-owned and state-owned Afghan depository institutions, are also authorized pursuant to GLs 16 and 20.  GL 20 also does not authorize transfers of luxury items or services to the Taliban, the Haqqani Network, any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, or any blocked individual who is in a leadership role of a governing institution in Afghanistan.  

For activity outside the scope of GLs 16 or 20, OFAC may issue specific licenses on a case-by-case basis to authorize certain transactions involving U.S. persons or the U.S. financial system that may otherwise be prohibited by OFAC sanctions, provided those transactions are in the foreign policy interests of the United States. 

Date Updated: February 25, 2022

For the purposes of Afghanistan-related GL 14, humanitarian assistance includes the provision of relief services related to natural and man-made disasters, the provision of healthcare and health-related services, protection and assistance for vulnerable or displaced populations (including women, individuals with disabilities, the elderly, survivors of violence, those incarcerated or detained, and the drug dependent), operation of orphanages, the distribution of articles (such as food, clothing, and medicine) intended to be used to relieve human suffering in Afghanistan, and training or other services related to any of the foregoing activities.  Other activities that support basic human needs include activities to support non-commercial development projects in Afghanistan that primarily benefit poor or at-risk populations or otherwise relieve human suffering, including activities related to shelter and settlement assistance, food security, livelihoods support, water, sanitation, health, hygiene, and COVID-19-related assistance, among others, and training or other services related to any of the foregoing activities.  However, in all cases, authorized humanitarian assistance and other activities that support basic human needs in Afghanistan must not entail financial transfers to the Taliban, the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest, other than for the purpose of effecting the payment of taxes, fees, and import duties, or the purchase or receipt of permits, licenses, or public utility services described in GL 14 and FAQ 928.

In addition, OFAC has issued Afghanistan-related GL 20, which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers humanitarian assistance to Afghanistan or other activities that support basic human needs in Afghanistan.

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorization in Afghanistan-related GL 14.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorization in GL 14.

For more information on relevant authorizations and guidance for providing humanitarian assistance to Afghanistan, please see OFAC’s humanitarian Fact Sheet, “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People,” (this content was updated on April 13, 2022) which provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. If individuals, nongovernmental organizations, international organizations, companies, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they can contact OFAC Compliance hotline. OFAC prioritizes license applications, compliance questions and other requests that are related to humanitarian support.

Date Updated: February 25, 2022

In July 2017, the United Kingdom Financial Conduct Authority (FCA) announced the “future cessation and loss of representativeness” of the ICE Benchmark Administration’s 35 global reference rates, the LIBOR rates.  In light of the discontinuation of LIBOR as a benchmark reference rate, OFAC is issuing additional guidance.   

The Belarus, Russia, Ukraine-/Russia-related, and Venezuela-related sanctions programs prohibit U.S. persons from dealing in certain new debt of persons identified as subject to these prohibitions.  In FAQ 944 (Belarus), FAQ 986 (Russia-related), FAQ 371 (Ukraine-/Russia-related), and FAQ 511 (Venezuela-related), OFAC provides examples of new debt, such as “bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper” issued on or after various specified dates.  For more information on the effective dates and relevant debt maturities for each of these sanctions programs, please see FAQ 947 (Belarus), FAQ 984 (Russia-related), FAQ 370 (Ukraine-/Russia-related), and FAQ 553 (Venezuela-related).

For the Belarus, Russia, Ukraine-/Russia-related, and Venezuela-related sanctions programs, OFAC has indicated that certain changes to contractual terms of loans, contracts, or other agreements that were entered into prior to the effective date of the relevant sanctions prohibitions could convert pre-existing debt that was not subject to the sanctions prohibitions into new debt that is subject to the sanctions prohibitions.  (See FAQ 947 (Belarus), FAQs 987 and 989 (Russia-related) FAQ 394 (Ukraine-/Russia-related), and FAQ 553 (Venezuela-related).

Loans, contracts, or other agreements that use LIBOR as a reference rate that are modified to replace such benchmark reference rate will not be treated as new debt for OFAC sanctions purposes, so long as no other material terms of the loan, contract, or agreement are modified.

Date Updated: February 24, 2022

The term debt includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper.  The term equity includes stocks, share issuances, depositary receipts, or any other evidence of title or ownership.

The prohibitions of Directive 1 apply to all transactions involving new debt of specified tenors (see FAQ 370) or new equity; all financing in support of such new debt or new equity; and any dealing in, including provision of services in support of, such new debt or new equity.  For example, for debt that is issued on or after November 28, 2017, on behalf of or for the benefit of a person subject to Directive 1, the maturity of such instrument must be 14 days or less in order for a U.S. person to transact in, to provide financing for, or to otherwise deal in such debt.

For debt that is issued on or after September 12, 2014 but before November 28, 2017, on behalf of or for the benefit of a person subject to Directive 1, the maturity of such instrument must be 30 days or less in order for a U.S. person to transact in, to provide financing for, or to otherwise deal in such debt.  If the terms of the agreement do not subsequently change as described in FAQ 394, then a U.S. person may deal in such debt even after the 14-day debt limit came into effect on November 28, 2017, because such debt would not constitute “new debt” for purposes of the sanctions applicable on or after November 28, 2017.

Likewise, for debt that is issued on or after July 16, 2014 but before September 12, 2014, on behalf of or for the benefit of a person subject to Directive 1, the maturity of such instrument must be 90 days or less in order for a U.S. person to transact in, to provide financing for, or to otherwise deal in such debt.  If the terms of the agreement do not subsequently change as described in FAQ 394, then a U.S. person may deal in such debt even after the revised tenors came into effect on September 12, 2014 or November 28, 2017, because such debt would not constitute “new debt” for purposes of the sanctions applicable on those dates.

The prohibitions of Directive 2 apply to all transactions involving new debt of specified tenors (see FAQ 370); all financing in support of such new debt; and any dealing in, including provision of services in support of, such new debt.

For example, for debt that is issued on or after November 28, 2017, on behalf of or for the benefit of a person subject to Directive 2, the maturity of such instrument must be 60 days or less in order for a U.S. person to transact in, to provide financing for, or to otherwise deal in such debt.

For debt that is issued on or after July 16, 2014 but before November 28, 2017, on behalf of or for the benefit of a person subject to Directive 2, the maturity of such instrument must be 90 days or less in order for a U.S. person to transact in, to provide financing for, or to otherwise deal in such debt.  If the terms of the agreement do not subsequently change as described in FAQ 394, then a U.S. person may deal in such debt even after the 60-day debt limit comes into effect on November 28, 2017 because such debt would not constitute “new debt” for purposes of the sanctions applicable on or after November 28, 2017.

The prohibitions of Directive 3 apply to all transactions involving new debt with a maturity of longer than 30 days; all financing in support of such new debt; and any dealing in, including provision of services in support of, such new debt.

All the prohibitions of these Directives extend to rollover of existing debt, if such rollover results in the creation of new debt with a maturity of longer than the applicable tenor specified in the relevant Directive (see FAQ 394).

Transacting in, providing financing for, or otherwise dealing in any debt issued by, on behalf of, or for the benefit of persons subject to Directives 1, 2, or 3, or equity issued by, on behalf of, or for the benefit of persons subject to Directive 1, is permissible if the debt or equity was issued prior to the date on which the person became subject to the relevant Directive.  In addition, transacting in, providing financing for, or otherwise dealing in debt instruments with tenors shorter than the specified tenors, even if they are issued after the sanctions effective date, is permissible.  Transacting in, providing financing for, or otherwise dealing in new equity instruments of persons subject to Directives 2 and 3 is permissible.  U.S. financial institutions may continue to maintain correspondent accounts and process U.S. dollar-clearing transactions for the persons subject to the Directives, so long as those activities:  (i) do not involve transacting in, providing financing for, or otherwise dealing in transaction types prohibited by these Directives; and (ii) are not prohibited by other sanctions authorities (see, e.g., FAQS 964 and FAQs 967 - 973).

In the case of Directive 1, transacting in, providing financing for, or otherwise dealing in debt with a maturity of 90 days or less (if issued on or after July 16, 2014 but prior to September 12, 2014) or 30 days or less (if issued on or after September 12, 2014 but prior to November 28, 2017) that was issued by, on behalf of, or for the benefit of the persons subject to Directive 1 is not prohibited if the terms of such instruments do not change subsequently (see FAQ 394 for additional detail on what constitutes the changing of terms).  Similarly, in the case of Directive 2, transacting in, providing financing for, or otherwise dealing in debt with a maturity of 90 days or less (if issued on or after July 16, 2014 but prior to November 28, 2017) that was issued by, on behalf of, or for the benefit of the persons subject to Directive 2 is not prohibited if the terms of such instruments do not change subsequently.  Rollovers of such instruments must comply with the new Directive 1 and 2 maturity limits that came into effect on November 28, 2017.

Date Updated: February 24, 2022

No.  The prohibitions of the Russia-related Sovereign Debt Directive apply only to bonds issued by, or loans made to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.  The prohibitions of the Russia-related Sovereign Debt Directive do not apply to the property or interests in property of those three entities.

Date Updated: February 22, 2022

Yes (see FAQ 888 and FAQ 965).

Date Updated: February 22, 2022