Frequently Asked Questions (FAQ)
On Tuesday, OFAC added another question to its FAQ for the Ukraine-related sanctions program: 418. How does OFAC interpret the term “shale projects” with respect to the prohibitions in Directive 4 under Executive Order 13662? The prohibitions in Directive 4 under Executive Order 13662 apply to deepwater, Arctic offshore, or […]
Check out how long the first sentence of the answer is… breathe! Question Relating to the Payments or the Facilitation of Payments to Iranian civil Aviation Authorities for Overflights of Iran or Emergency Landing in Iran Print This entire FAQ topic 417. Are payments or the facilitation of payments to […]
402. How does OFAC’s 50 Percent Rule apply to situations in which one or more blocked persons owned 50 percent or more of an entity, but subsequent to their designations one or more blocked persons divest their ownership stakes in the entity in a transaction that occurs entirely outside of […]
400. As explained in FAQ 398, OFAC’s 50 Percent Rule does not apply if one or more individuals who are blocked persons (blocked individuals) control, but do not own 50 percent or more of, an entity. Can persons engage in negotiations, enter into contracts, or process transactions involving a blocked […]
398. Does OFAC consider entities over which one or more blocked persons exercise control, but do not own 50 percent or more of, to be blocked pursuant to OFAC’s 50 Percent Rule? No. OFAC’s 50 Percent Rule speaks only to ownership and not to control. An entity that is controlled […]
Yesterday, OFAC issued updated guidance on “Entities Owned by Persons Whose Property and Interests in Property Are Blocked” – and an FAQ: These Frequently Asked Questions (FAQs) respond to inquiries received by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) relating to the status of entities owned […]
Here's the new section, in its entirety: Questions Related to Sectoral Sanctions under Executive Order 13662 Print This entire FAQ topic 370. What is this prohibition under Executive Order (E.O.) 13662? Is it a blocking action? The sanctions imposed today on specified persons operating in sectors of the Russian economy […]
From the FAQ: 374. If I own a Kalashnikov product, is that product blocked by sanctions? Am I able to resell a Kalashnikov product at a gun show or other secondary market? If a U.S. person is in possession of a Kalashnikov Concern product that was bought and fully paid […]
From the FAQ: 373. Do the prohibitions under E.O. 13662 also extend to debt and equity issued by entities owned 50 percent or more by the entities identified by this order, as per guidance OFAC issued on February 14, 2008? Yes, this prohibition applies to the named persons, their property, […]
From the FAQ: 372. Does today’s action prohibit U.S. persons from entering into derivatives contracts linked to debt or equity issued on or after July 16, 2014 by the entities identified today? The action taken today under E.O. 13662 is solely a prohibition on transacting in, providing financing for, or […]
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