Mr. Sanctions

Category: Frequently Asked Questions (FAQs)

  • September 16, 2026: OFAC Update Part 2: Venezuela General License 5 versions goes to Z, and the amended FAQ

    GL 5 has been updated to GL 5Z:

    venezuela_gl5zDownload

    And Frequently Asked Question 595 got updated, too:

    595. What does Venezuela-related General License 5Z authorize?

    Answer

    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    General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license.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

    Date Released

    January 20, 2022

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  • September 14, 2026: OFAC Update, Part 2: New Version of Venezuela GL and updated FAQ

    Today, OFAC updated Venezuela-related General License 52C (Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.):

    venezuela_gl52cDownload

    Additionally, Frequently Asked Question 1245 was updated:

    1245. What activities are authorized by Venezuela General License (GL) 52C, “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.”?

    Answer

    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

    Date Released

    March 18, 2026

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  • September 9, 2026: OFAC Update, Part 2: FAQ-a-palooza!

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is amending several Frequently Asked Questions (FAQs) today (5, 13, 51, 58, 59, 74, 75, 76, 77, and 78) as part of its ongoing process of reviewing published guidance to ensure information remains current. This batch includes review of OFAC’s FAQ topic pages, OFAC Licenses, and Assessing OFAC Name Matches. OFAC is also publishing two new license-related FAQs (FAQs 1269 and 1270).

    Here are the two new FAQs – 1269:

    1269. How do I find the case identification (“Case ID”) number for my license application? Is it different from the Reference ID or Application Alias in my original application?

    Answer

    Case Identification Number: Once OFAC receives and begins to process your specific license application, OFAC’s Licensing Division will assign a case identification (“Case ID”) number. This number will be in the Year-Case ID format (i.e., YYYY-9999999). Note the Case ID number is different from the Reference ID that was created when you submitted your application. Please take note of the Case ID as you will need to reference it throughout the application process, including to view your application’s status. For more information on checking the status of your specific license application, see FAQ 77 or the OFAC Specific Licenses and Interpretive Guidance page on OFAC’s website.

    Reference ID: A Reference ID helps with the tracking and processing of your application until OFAC provides a Case ID. You may request to receive an email confirming OFAC’s receipt of your application upon submission, which will include your Reference ID. The Reference ID is also listed in the PDF copy of your submission, which is displayed on the screen confirming that your application was successfully submitted to OFAC.

    If you submitted your specific license application as a guest user, you were asked to create a unique Reference ID for your application. OFAC’s Licensing Division will contact you to provide a Case ID when it is assigned to your application.

    If you submitted your specific license application through an account, a unique Reference ID was automatically assigned to your application. When a Case ID is assigned to an application, it will automatically be reflected in your “My Applications” account dashboard.

    Application Alias: If you submitted your specific license application through an account, you may have created an Application Alias to help easily identify and differentiate it among your applications when viewing your “My Applications” account dashboard.  The Application Alias is not included in your application or tracked by OFAC.

    Note that if you are submitting questions to the OFAC Licensing Hotline, you should refer to one of the above numbers, preferably the Case ID if you have received one, within your submission.  You may contact the OFAC Licensing Hotline for specific licensing-related questions.

    Date Released

    September 9, 2026

    and 1270:

    1270. How can I get my OFAC specific license amended or renewed?

    Answer

    If you currently have a specific license from OFAC and seek to amend the terms of the license due to a change in circumstance, or wish to renew or extend the license’s expiration date, please visit the OFAC Specific Licenses and Interpretive Guidance page on OFAC’s website and submit the same type of application as your current license (e.g., Transactional). You should reference your current license in the “Previous License Number” field.

    Where applicable, OFAC recommends you apply at least 60 days prior to the current specific license’s expiration date to avoid a lapse in authorization.

    Date Released

    September 9, 2026

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  • September 2, 2026: Finally – OFAC reminds you of the ARBP filing, issues new versions of Venezuela GLs, and amends a related FAQ

    Reminder to file the 2026 Annual Report of Blocked Property; Issuance of Amended Venezuela-related General Licenses and Frequently Asked Question

    09/02/2026

    Recent Actions Body

    On July 1, 2026, the Office of Foreign Assets Control (OFAC) issued a recent actions notice, reminding U.S. persons holding blocked property as of June 30, 2026, to file an Annual Report of Blocked Property (ARBP) no later than September 30, 2026. Failure to file the ARBP by September 30 may lead to an enforcement referral.

    For additional information, please review OFAC’s Guidance on Filing the 2026 Annual Report of Blocked Property.

    Additionally, OFAC is issuing Venezuela-related General License 51D, “Authorizing Certain Activities Involving Venezuelan-Origin Coal or Minerals, Including Gold;” Venezuela-related General License 54C, “Authorizing the Supply of Certain Items and Services for Coal or Minerals Operations in Venezuela;” and Venezuela-related General License 55A, “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Coal or Minerals Sectors.”

    Lastly, OFAC has amended one Venezuela-related Frequently Asked Question, FAQ 1247.

    The guidance:

    arbp_guidance_2026Download

    GL 51D:

    venezuela_gl51dDownload

    GL 54C:

    venezuela_gl54cDownload

    GL 55A:

    venezuela_gl55aDownload

    and the FAQ:

    1247. Do non-U.S. persons face sanctions risk for engaging in transactions authorized by General Licenses (GL) 46D, 51D, and 52B? 

    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

    Updated on Sep 02, 2026

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  • August 27, 2026: Got Wite-Out? OFAC issues new versions of 8 Venezuela General Licenses, issues 2 new FAQs, amends 2, and archives 1 – and Claude explains the changes

    Issuance of Amended Venezuela-related General Licenses and Associated Frequently Asked Questions

    Release Date

    08/27/2026

    Recent Actions Body

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Venezuela-related General License 46D, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products;” Venezuela-related General License 47B, “Authorizing the Sale of U.S.-Origin Diluents to Venezuela;” Venezuela-related General License 48C, “Authorizing the Supply of Certain Items and Services to Venezuela;” Venezuela-related General License 50C, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities;” Venezuela-related General License 51C, “Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold;” Venezuela-related General License 52B, “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.;” Venezuela-related General License 54B, “Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela;” and Venezuela-related General License 61A, “Authorizing the Supply of Certain Items and Services to Venezuela Related to Telecommunications.”

    Additionally, OFAC is issuing two new Venezuela-related Frequently Asked Questions (FAQs 1267 and 1268), amending two Venezuela-related Frequently Asked Questions (FAQs 1233 and 1244), and archiving FAQ 1260.

    Claude explains the difference:

    What’s new is that OFAC fully removed the separate governing-law requirement, the clause requiring contract terms to be “construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States.” So the two conditions that used to travel together (US governing law + dispute resolution venue) have been decoupled, and only the dispute-resolution piece survives. That’s the substantive change behind your two new FAQs:

    • FAQ 1267 (new): Asks whether the amended GLs still require a choice-of-law provision. Answer: no, effective Aug 27, 2026. OFAC states the rationale as responding to “investment-related reforms made by the GOV since January 2026.” It doesn’t name Venezuela’s Hydrocarbons Law amendment specifically, so connecting the two is my inference based on outside reporting, not something OFAC states in the FAQ itself.
    • FAQ 1268 (new): Confirms the dispute-resolution-venue requirement itself is untouched, and adds a clarifying line that the requirement “relates to the jurisdiction in which dispute resolution proceedings must occur, rather than the law governing the underlying contract.”

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  • August 21, 2026: OFAC issues 2 new Venezuela General Licenses and one new Frequently Asked Question

    On Friday, OFAC issues Venezuela GL 61 (Authorizing the Supply of Certain Items and Services to Venezuela Related to Telecommunications):

    venezuela_gl61Download

    and GL 62 (Authorizing Negotiations of and Entry Into Contingent Contracts for Investment in the Telecommunications Sector of Venezuela):

    venezuela_gl62Download

    and, for good measure, FAQ 1266:

    1266. What activities does Venezuela General License (GL) 61 authorize?

    Answer

    GL 61 authorizes transactions ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the installation, maintenance, refurbishment, repair, upgrade, operation, or support of telecommunications in Venezuela, including transactions involving the Government of Venezuela, including but not limited to the Comisión Nacional de Telecomunicaciones (CONATEL), Compania Anonima Nacional Telefonos de Venezuela (CANTV), and Movilnet.

    For purposes of GL 61, telecommunications includes data, telephone, internet connectivity, radio, television, news wire feeds, and similar services, regardless of the medium of transmission, including transmission by satellite or through submarine cables.

    Authorized transactions include:  processing payments and arranging shipping, including air freight, logistics, warehousing, insurance, and delivery services; interconnection and roaming agreements; capacity or infrastructure leases; and the laying, maintenance, repair, refurbishment, upgrade, security, operation, or support of submarine cables and other telecommunications infrastructure or equipment; and the provision, licensing, renewal, maintenance, or support of related software, systems, and services, including software updates and network-support services.  The provision of other financial services for the refurbishment, repair, upgrade, operation, or support of telecommunications in Venezuela would also be authorized to the extent ordinarily incident and necessary to the authorized telecommunications-related activity and provided that it does not involve debt swaps or other payment terms prohibited by GL 61.

    Examples of transactions authorized by GL 61 include those ordinarily incident and necessary to the provision of:

    • telecommunications equipment and network infrastructure, including broadband access equipment, components, and spare parts;
    • telecommunications capacity or infrastructure through leases, including fiber-optic pairs and satellite bandwidth;
    • international telecommunications connectivity, including IP transit;
    • telecommunications-related:
      • software, including licensing, renewals, updates, maintenance, and technical or vendor support;
      • cloud services;
      • data storage and backup systems, network monitoring and automation platforms;
      • customer billing systems; and
    • servers and other computing systems used to support telecommunications.

    Notably, GL 61 does not authorize:

    • payment terms that are not commercially reasonable, involve debt swaps or payments in gold, or are 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 or organized under the laws of Russia, Iran, North Korea, Cuba, or the People’s Republic of China, or an entity owned or controlled, directly or indirectly, by or in a joint venture with such a person;
    • the unblocking of property blocked pursuant to the Venezuela Sanctions Regulations;
    • transactions involving blocked vessels; or
    • the formation of new joint ventures or other entities in Venezuela to develop or invest in the telecommunications sector.

    Date Released

    August 21, 2026

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  • August 20, 2026: OFAC Update, Part 2: New version of Russian GL131, and 3 amended FAQs (2 Russian, 1 Cuban)

    While Claude is chugging through the massive update today (a press chart, 2 Treasury PRs, 3 State PRs, and a fact sheet), I’m going to post the other part…

    First, Russia-related General License 131I (Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities):

    russia_gl131iDownload

    And OFAC updated 2 related Russian Frequently-Asked Questions again – 1224:

    1224. What negotiations does Russia-related General License 131I authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?

    Answer

    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) 131I, 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 131I expires on September 19, 2026.

    GL 131I 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 131I 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 131I 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: August 20, 2026

    Date Released

    November 19, 2025

    and 1225:

    1225. What activities do Russia-related General License 128C and General License 131I authorize related to Lukoil International GmbH (LIG)?

    Answer

    OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128C and GL 131I. 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 to extend the existing authorization until October 29, 2026.
    • 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, and GL 131I, to extend the existing authorization until September 19, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

    GL 128C and GL 131I 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 128C and GL 131I. 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 128C and GL 131I 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 128C and GL 131I 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 128C and GL 131I. Similarly, non-U.S. persons may rely upon GL 128C and GL 131I 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 128C and GL 131I, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

    Date Updated: August 20, 2026

    Date Released

    December 4, 2025

    as well as Cuba FAQ 1265:

    1265. On August 20, 2026, the Department of State designated the Ministry of Construction of Cuba (MICONS) pursuant to E.O. 14404.  Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with MICONS?

    Answer

    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 wind down of transactions involving MICONS, or any entity in which MICONS owns, directly or indirectly, a 50 percent or greater interest, through September 19, 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 wind down transactions involving MICONS, or any entity in which MICONS owns, directly or indirectly, a 50 percent or greater interest, before September 19, 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 MICONS, including in connection with a non-U.S. person’s wind down of activities with MICONS, absent OFAC authorization. Relevant authorizations may include humanitarian-related transactions authorized under the CACR in subpart E of part 515 and under E.O. 14404 via General License (GL) 1.  For additional information on GL 1, see FAQ 1253. 

    Date Released

    August 20, 2026

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  • August 7, 2026: OFAC Update, Part 2: Amended Iran-related Frequently Asked Question

    Today, OFAC amended FAQ 1257:

    1257. Are non-U.S. persons exposed to sanctions for dealing with digital asset exchanges designated pursuant to Executive Order 13902, “Imposing Sanctions with Respect to Additional Sectors of Iran” (E.O. 13902)?

    Answer

    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

    Date Released

    June 2, 2026

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  • August 6, 2026: OFAC Update, Part 2: a new Cuba Frequently Asked Question

    FAQ 1264 states:

    1264. I am a non-U.S. person engaged in humanitarian activities specifically looking to send food, medicine, or medical devices to Cuba. What is my exposure to sanctions under Executive Order (E.O.) 14404? 

    As a general matter, U.S. sanctions under E.O. 14404 are not focused on disrupting the delivery of food, medicine, or medical devices to Cuba. The U.S. government does not intend to target non-U.S. persons under E.O. 14404 for engaging in transactions related to the provision, directly or indirectly, of agricultural commodities, including food, as well as medicine, medical devices, replacement parts and components for medical devices, and software updates for medical devices, to Cuba. This non-targeting posture includes those described humanitarian-related transactions that involve a person designated pursuant to E.O. 14404, or entities in which such persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.

    Consistent with humanitarian authorizations related to agricultural commodities, medicine, and medical devices issued by the Office of Foreign Assets Control (OFAC) for other sanctions programs under the International Emergency Economic Powers Act (IEEPA), OFAC interprets those terms for purposes of E.O. 14404 as follows:

    Agricultural commodities: Agricultural commodities are products that fall within the term “agricultural commodity” as defined in section 102 of the Agricultural Trade Act of 1978 (7 U.S.C. 5602) and are intended for use as:

    • Food for humans (including raw, processed, and packaged foods; live animals; vitamins and minerals; food additives or supplements; and water) or animals (including animal feeds);
    • Seeds for food crops;
    • Fertilizers or organic fertilizers; or
    • Reproductive materials (such as live animals, fertilized eggs, embryos, and semen) for the production of food animals.

    Medicine: Medicine is an item that falls within the definition of the term “drug” in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321).

    Medical devices: A medical device is an item that falls within the definition of “device” in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321).

    Any U.S. person involvement in such transactions must comply with authorizations and requirements in Cuba-related General License (GL) 1. See FAQ 1253 for additional information on GL 1. As of August 2026, the U.S. government is working to operationalize $100 million in humanitarian assistance directly to the Cuban people, delivered through independent organizations operating under appropriate authorizations, including those operating as contractors or grantees on official U.S. government business.

    For non-U.S. persons engaged in humanitarian-related activity that may fall outside the scope outlined in this Frequently Asked Question, OFAC considers requests on a case-by-case basis, prioritizing those requests that are related to humanitarian activity. Non-U.S. persons may contact the OFAC Compliance Hotline with additional information.

    Released on Aug 06, 2026

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  • August 3, 2026: Y?

    Yes, OFAC’s Venezuela GL 5 is up to the Y revision:

    venezuela_gl5yDownload

    and there is an updated FAQ 595, too

    595. What does Venezuela-related General License 5Y authorize?

    Answer

    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 5Y on August 3, 2026, which further delays the effectiveness of the authorization in GL 5 until September 17, 2026. Between October 24, 2019 and September 17, 2026 (the date the authorization in General License 5Y 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: August 03, 2026

    Date Released

    January 20, 2022

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