Eleven Questions Practitioners Keep Asking OFAC

OFAC’s FAQ database now runs to roughly 985 entries spread across 38 topic pages, from a single FAQ under Balkans-Related Sanctions to 243 under Iran. Read across the whole set, the same handful of question types show up again and again, program after program. Below are the eleven categories that emerged from that review, ordered from most to least common, with a rough sense of how much of the database each one accounts for.

A caveat up front: these categories aren’t mutually exclusive. A single FAQ interpreting a Russia general license is very often also a secondary-sanctions question and a wind-down question at the same time. The counts below are estimates based on which category each FAQ most centrally addresses, not a mechanical tag count, so treat them as directional rather than exact.

1. What does General License X authorize? (~340 FAQs, the largest category by far)

This is the single most common reason an OFAC FAQ exists. A general license gets issued, and OFAC follows it with one or more FAQs spelling out exactly what it covers, what it doesn’t, and how long any wind-down window runs. These FAQs are almost never abstract – they’re triggered by one specific GL and answered in narrow, GL-specific terms. Belarus GL 4 and GL 5 (the Belaruskali wind-down), Russia GL 8L (energy wind-down) and GL 116 (entities linked to a specific designated individual), and the Afghanistan GLs 14 through 20 are all typical examples. If you’re trying to predict where OFAC will publish its next FAQ, a newly issued GL is usually the leading indicator.

2. Secondary sanctions and non-U.S. person exposure (~100 FAQs)

Concentrated heavily in Iran and Russia. These FAQs work through when a non-U.S., non-Iranian, or non-Russian person or financial institution can be exposed to U.S. sanctions for dealing with a blocked party – CISADA, the NDAA “significant transaction” test, and the Russia-related CAPTA Directive all generate this type of question repeatedly. A cluster of these FAQs exists purely to define the operative terms (what counts as “significant,” what “knowingly” means) because those definitions are what determine whether a foreign bank loses U.S. correspondent account access.

3. Wind-down and divestment mechanics (~100 FAQs)

Distinct from the general GL-scope questions above: these are about the lifecycle of a transaction after a designation happens – closing a correspondent account, paying down an outstanding loan, or negotiating the sale of a now-blocked entity. The recent Lukoil-related FAQs on divesting LIG entities are a good current example of this pattern.

4. Humanitarian and agricultural/medical carve-outs (~80 FAQs)

Nearly every country program has its own version of this question, because food, medicine, and medical device exports are treated as a standing exception that industry keeps asking about program by program – Afghanistan, Iran, Russia, Cuba, Venezuela, and Sudan all have a meaningful cluster here.

5. Highly bespoke, single-entity FAQs (~80 FAQs)

Especially visible in Iran and Russia: FAQs that read more like case notes on one company or one enforcement action than generalizable guidance – the Bank of Kunlun CISADA finding is a good example. This pattern is likely a big part of why Iran (243 FAQs) and Russia (159 FAQs) so heavily outweigh every other topic: long-running programs accumulate a one-off FAQ per major action rather than folding it into a general rule.

6. Definitional FAQs (~70 FAQs)

A surprising share of FAQs exist purely to pin down a term used in a statute or executive order – “significant financial transaction,” “knowingly,” “Iranian financial institution,” “Russia’s military-industrial base.” These read like industry asked for definitional certainty before OFAC ever issued formal regulatory text on the point, and OFAC answered by FAQ instead.

7. The 50 Percent Rule and entity ownership (~50 FAQs)

Some version of “is this entity blocked because a blocked person owns 50 percent or more of it, directly or indirectly through another entity” shows up in nearly every topic – Basic Information, Belarus, Iran, Russia, Afghanistan, and its own dedicated topic (Entities Owned by Blocked Persons). This is clearly one of the more persistently confusing mechanics in the whole sanctions regime, and OFAC keeps restating the same core rule with slightly different fact patterns each time.

8. Correspondent and payable-through account mechanics (~50 FAQs)

A process-level companion to the secondary sanctions category above: what a U.S. financial institution must actually do if it holds an account, or receives a wire, touching a blocked or listed party – block it, reject it, report it to OFAC within 10 business days, and hold it in an interest-bearing account pending further action.

9. SDN List mechanics and name-matching (~50 FAQs)

Assessing OFAC Name Matches is an entire topic devoted to this question, and it recurs elsewhere too – what the bracketed program tags on an SDN List entry mean (e.g., [IRAN], [IFSR], [SDGT]), how the delisting and reconsideration process works, and OFAC’s consistent point that it does not publish or endorse any kind of “safe list.”

10. Building and running a compliance program (~40 FAQs)

A separate cluster from the transaction-specific questions above – Starting an OFAC Compliance Program is its own topic, and there are sector-specific versions for insurance and for internet/web-based activity. These are less about a specific designation and more about internal controls generally.

11. Sector determinations (~30 FAQs)

“OFAC identified Sector X of a country’s economy – does that mean everyone in that sector is blocked?” Burma’s jet fuel sector, Russia’s metals and mining sector, and Belarus’s potash sector all generate this question. OFAC’s answer follows the same pattern each time: identifying a sector puts persons operating in it on notice of sanctions risk, but it does not automatically block everyone in that sector – only persons OFAC actually designates.

---

A note on the numbers. The estimates above add up close to the full 985-FAQ database, but they shouldn’t be read as an exact partition – plenty of individual FAQs genuinely straddle two or three of these categories.