Mr. Sanctions

Category: Frequently Asked Questions (FAQs)

  • July 24, 2026: OFAC Update, Part 2: New Version of Russian GL, amended Russia and Venezuela FAQs, and final rule to update and correct CFR

    Today, OFAC issued Russian-related General License 131H:

    Russia_gl131HDownload

    and amended related Frequently Asked Questions 1224:

    1224. What negotiations does Russia-related General License 131H 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) 131H, 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 131H expires on August 22, 2026.

    GL 131H 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 131H 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 131H 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: July 24, 2026

    Date Released

    November 19, 2025

    and 1225:

    1225. What activities do Russia-related General License 128C and General License 131Hauthorize 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 131H. 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, and GL 131H, to extend the existing authorization until August 22, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

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

    Date Updated: July 24, 2026

    Date Released

    December 4, 2025

    as well as Venezuela FAQ 1239:

    1239. Where can I find the account information to make authorized payments to the Foreign Government Deposit Funds deposit account, as specified in Executive Order 14373?

    Answer

    To obtain payment account information for payments to the Foreign Government Deposit Funds deposit account established consistent with Executive Order (E.O.) 14373, “Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People,” and referenced in certain Venezuela General Licenses, depositors must first email the official point of contact for the deposit account at: DepositorInquiries@state.gov. Potential depositors that fail to contact this email inbox and provide the requested transaction details may have their deposits rejected. Potential depositors should be prepared to provide all relevant transaction details, including the following, as appropriate:

    • Full legal names and addresses of corporate depositor and all contract parties (provide subsidiary information, as applicable);
    • Detailed description of the underlying contract or obligation, including the purpose and nature of the payment (include information on the type of product and amount purchased and/or sold);
    • Date of sale and copies of the corresponding invoice(s), contract number(s), and any relevant reference identifiers;
    • Total payment amount, currency, and proposed payment date(s);
    • Identification of the license authorizing the transaction;
    • Copies of any other transaction record(s) to validate the deposit; and
    • Primary point of contact for any follow-up questions, including name, title, telephone number, and email address.

    Once the Department of State has provided payment account information and the deposit has been made and accepted, the depositor will receive a confirmation email acknowledging the deposit, which can be used to inform all contract parties involved in the transaction.

    Date Updated: July 24, 2026

    Date Released

    March 4, 2026

    Finally, OFAC issued a new final rule:

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is adopting a final rule to update website and contact information in certain parts of the Code of Federal Regulations (CFR). Additionally, OFAC is amending one CFR part to update general licenses authorizing payments for legal services from funds originating outside the United States to replace the reporting requirement in the general license with a recordkeeping requirement and correcting typographical errors in two CFR parts. OFAC is also updating a part of 31 CFR chapter V to correct an erroneous cross-reference.

    Here’s the final rule:

    fr_Updating Website and Contact Information, and Authorizations for Payments for Legal ServicesDownload

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  • July 21, 2026: OFSI adds 6 new FAQs on BNAs

    Office of Financial Sanctions Implementation HM Treasury

    6 FAQs added on Basic Needs Allowance (BNA)

    OFSI has published FAQs 197-202 on Basic Needs Allowance (BNA) licences, which permit designated persons to access a capped monthly sum from frozen funds for essential living expenses. OFSI benchmarks the BNA against median household income. In many cases, including those involving high net worth individuals, the BNA will not provide for the continuation of a pre-designation standard of living.

    FAQs 197-202 cover the purpose and scope of BNA licences, permitted expenditure, reporting requirements, treatment of monthly underspend, and how costs falling outside the BNA may be licensed separately.

    The guidance is relevant to designated persons and any party facilitating payments under a BNA licence.

    The FAQs:

    Basic Needs Allowance

    197. What is a basic needs allowance licence?

    A Basic Needs Allowance (BNA) licence is a type of specific licence which OFSI may issue under the basic needs licensing ground across all non-counter-terrorism sanctions regimes. It permits a designated person (DP) to access a capped monthly sum from their otherwise frozen funds to meet essential day-to-day living expenses. OFSI benchmarks the allowance to reflect a median income household rather than the DP’s previous lifestyle or claimed expenditure.  Rent or mortgage payments are considered separately from the BNA and assessed on a case-by-case basis.

    Added on: 21 Jul 2026

    198. What is the purpose of the basic needs allowance?

    The basic needs allowance is intended to help ensure that a DP and any financially dependent family members can meet their day-to-day living costs, broadly in line with a median-income household. It is not intended to enable a DP to maintain the lifestyle, wealth, or business activities they enjoyed prior to designation.

    DPs applying for or operating under a BNA licence should ensure that expenditure remains consistent with this purpose. Any party facilitating payments under a BNAlicence should similarly satisfy itself that the payments fall within the terms and purpose of the licence.

    Added on: 21 Jul 2026

    199. Do basic needs allowance licences include reporting requirements?

    Yes. Basic needs allowance licences include reporting conditions requiring expenditure to be evidenced and reported to OFSI. This is a proportionate method that enables OFSI to maintain oversight of the usage of the licence and may inform any future decision when licences are renewed or varied.

    Applicants should be prepared to comply with any reporting requirements imposed as conditions of a licence. Compliance with those conditions does not guarantee that a licence will be renewed or varied.

    Added on: 21 Jul 2026

    200. What can the basic needs allowance be spent on?

    OFSI does not provide an exhaustive list of approved purchases. A DP has broad discretion, though not total, in how the allowance is used. That discretion is limited by the terms of the licence, the relevant sanctions regulations, and the purpose for which the licence is granted

    The allowance is intended to cover goods and services that reasonably constitute basic needs. This may include (but is not limited to) food, clothing, personal hygiene, local transport, basic household items, and hairdressers. It does not cover expenditure that falls outside the terms of the basic needs licencing purpose, nor expenditure which would otherwise breach the financial sanction’s regime.  

    Some discretionary spending may be consistent with the terms of a BNA where it supports basic family life and remains proportionate to the benchmark of a median-income household. This may include recreation, education, leisure, and other miscellaneous goods and services. Whether such expenditure is appropriate will depend on the circumstances and must remain consistent with the purpose of the licence.

    Added on: 21 Jul 2026

    201. Does the basic needs allowance licence permit carry-over of any monthly underspend?

    No. Each month’s allowance is a fixed, standalone cap. If a DP does not use the full allowance in a given month, the unspent amount cannot be carried forward or added to the following month’s allowance. The monthly cap resets at the start of each new month.

    Added on: 21 Jul 2026

    202. Does OFSI license costs separately that may fall outside of the core basic needs allowance?

    Yes. Where a cost cannot reasonably be met from the basic needs allowance, OFSI may consider a separate licence application. Such applications are assessed on their individual merits and approval is not automatic.

     OFSI will consider whether the relevant cost could reasonably be met from within the basic needs allowance. In particular, OFSI will assess whether the expenditure is of a type that a median-income household would ordinarily absorb through routine day-to-day spending.

    Where a cost could reasonably be met from the basic needs allowance, OFSI would generally expect it to be funded from that allowance rather than licensed separately.

    Applicants seeking separate licensing should therefore explain why the expenditure cannot reasonably be met from the basic needs allowance, how the relevant licensing purpose is met, and provide supporting evidence where appropriate. Applications can be submitted via OFSI’s application form at: OFSI launches online forms for reporting and licences – Office of Financial Sanctions Implementation.

    Added on: 21 Jul 2026

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  • July 17, 2026: OFAC issues new Venezuela Frequently Asked Question

    It’s FAQ 1263:

    1263. Does General License (GL) 60 require that payments to the Government of Venezuela be made into the Foreign Government Deposit Funds Account (FGDF)?

    Answer

    No. GL 60 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 60 do not need to be paid into the FGDF.

    However, the requirements under other Venezuela-related GLs, such as GLs 46C, 48B, 49A, 50B, 51B, 52A, and 54A, remain in place. Payments for activities outside of the scope of GL 60 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 Released

    July 17, 2026

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  • July 13, 2026: OFAC Update, Part 2: New OFAC Cuba-related Frequently Asked Question

    It’s FAQ 1262:

    1262. On July 13, 2026, the Department of State designated the Cuban entities Grupo Empresarial del Comercio Exterior (GECOMEX) and Grupo Empresarial de Transporte Marítimo Portuario (GEMAR) pursuant to E.O. 14404. Are non-U.S. persons, including foreign financial institutions (FFIs), exposed to sanctions risk for winding down transactions with GECOMEX or GEMAR? 

    The U.S. government does not intend to target non-U.S. persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the wind down of transactions involving GECOMEX, GEMAR, or any entity in which either GECOMEX or GEMAR owns, directly or indirectly, a 50 percent or greater interest, through August 12, 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 GECOMEX, GEMAR, or any entity in which either GECOMEX or GEMAR owns, directly or indirectly, a 50 percent or greater interest, or transfer such assets to another jurisdiction could expose non-U.S. persons to significant sanctions risk.

    Non-U.S. persons unable to wind down transactions involving GECOMEX, GEMAR, or any entity in which either GECOMEX or GEMAR owns, directly or indirectly, a 50 percent or greater interest, before August 12, 2026, are encouraged to contact the OFAC Compliance Hotline.

    Persons subject to U.S. jurisdiction, including U.S. entities owned or controlled by U.S. persons, have long been prohibited pursuant to the Cuban Assets Control Regulations (CACR), 31 CFR part 515, from transacting with GECOMEX and GEMAR, absent OFAC authorization. Accordingly, persons subject to U.S. jurisdiction continue to be prohibited from engaging in transactions involving GECOMEX or GEMAR, including in connection with a non-U.S. person’s wind down of activities with GECOMEX or GEMAR, unless separately authorized by OFAC. 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.

    Released on Jul 13, 2026

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  • Burning Question: What kind of OFAC FAQs are there?

    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.

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  • July 8, 2026: Another 3 months for OFAC Russia-related GL 13… and 2 updated FAQs

    Today, OFAC issued Russia-related General License 13R:

    russia_gl13rDownload

    and updated 2 Frequently Asked Questions:

    1118. As of December 2022, the Government of the Russian Federation may require a so-called “exit tax” payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called “exit tax”? Does Russia-related General License (GL) 13R authorize transactions that involve the payment of this exit tax? 

    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

    Updated on Jul 08, 2026

    Russian Harmful Foreign Activities Sanctions

    999. What authorizations exist for entities subject to 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)? 

    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) 115D 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 13R 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 13R, 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 13R, GL 14, GL 115D, and GL 132 continue to authorize against the Russia-related Sovereign Transactions Directive.

    Date Updated: July 08, 2026

    Updated on Jul 08, 2026

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  • Burning Question: OFAC FAQs, by the numbers

    OFAC_FAQ_TopicsDownload

    The spreadsheet lists all OFAC Frequently Asked Questions Topics and the number of FAQs for each topic, sorted in descending order. Not totally surprising, but Iran sanctions (243) and Russia sanctions (159) top the list.

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  • June 25, 2026: OFAC Update, Part 2: New Version of Russian-related General License 131 and 2 updated FAQs

    Here’s GL 131G:

    russia_gl131gDownload

    And updated FAQs 1224 and 1225:

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

    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 131G. 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, 131E, 131F, and 131G to extend the existing authorization until July 25, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

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

    Date Updated: June 25, 2026

    Updated on Jun 25, 2026

    Russian Harmful Foreign Activities Sanctions

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

    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) 131G, 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 131G expires on July 25, 2026.

    GL 131G 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 131G 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 131G 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: June 25, 2026

    Updated on Jun 25, 2026

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  • June 24, 2026: OFSI amends Prince Group Insolvency General Licence and add a new Russia-related FAQ

    Office of Financial Sanctions Implementation HM Treasury

    OFSI General Licence – INT/2026/9491628

    amended and 1 FAQ added

    OFSI has published the amended Prince Group Insolvency General Licence INT/2026/9491628.

    The General Licence was amended as follows:

    The definition of ‘Permitted Insolvency Activities’ was amended to “The making, receiving, or processing of payments and any other action that is in connection with the Insolvency Proceedings, whether prior to or after commencement of such proceedings, conducted at the direction of, or with the consent of an Insolvency Practitioner (or Practitioners), are permitted, provided that no funds or economic resources are made available (directly or indirectly) to or for the benefit of any DP other than a Prince Group DP or Subsidiary.”

    For the avoidance of doubt, the above definition only applies where the Insolvency Practitioner (or Practitioners) continue to act in that capacity in relation to the Insolvency Proceedings.

    Consequential amendments were made to remove references to ‘any DP’ in the permissions, notification and record-keeping requirement.

    Here’s the amended GL:

    Prince_Group_Insolvency_-_INT-2026-9491628_GLDownload

    OFSI has published a new FAQ – FAQ 196 – on the amendment to the Continuation of Business of Lukoil International Entities General Licence (INT/2025/8031092), which was amended on 19 June 2026 to remove the requirement that funds made available, directly or indirectly, to or for the benefit of Lukoil International GmbH or a Lukoil International subsidiary must be paid into a frozen account.

    It remains the case that funds must not be made available to or for the benefit of PJSC Lukoil, the designated Russian parent company, under General Licence INT/2025/8031092.

    Any persons intending to use General Licence INT/2025/8031092 should consult FAQ 196and the copy of the Licence for full details of the permissions and usage requirements.

    The FAQ:

    196. Why did OFSI amend General Licence INT/2025/8031092 on 19 June 2026?

    On 19 June 2026, OFSI amended General Licence INT/2025/8031092 to remove the requirement that funds made available, either directly or indirectly, to or for the benefit of Lukoil International GmbH or a Lukoil International subsidiary must be paid into a frozen account.

    The frozen account requirement meant that counterparties making payments and transfers to Lukoil International subsidiaries under existing or new obligations or contracts were required to pay those funds into frozen accounts. Removing this requirement allows Lukoil International subsidiaries to access funds needed to meet operational costs, including payments to staff, suppliers and essential services, and supports the viability of Lukoil International’s assets whilst sale negotiations are underway.

    OFSI notes the broader context of reported interest in the potential sale of PJSC Lukoil’s international assets and the importance of facilitating an orderly transition whilst balancing the energy security of third parties and the need of those assets to meet essential operational costs.

    It remains the case that funds must not be made available to or for the benefit of PJSC Lukoil, the designated Russian parent company, under General Licence INT/2025/8031092.

    Users of General Licence INT/2025/8031092 should carefully consider all relevant conditions of the amended licence.

    HM Treasury may vary, revoke or suspend General Licence INT/2025/8031092 at any time.

    Added on: 24 Jun 2026

    and the referenced General Licence:

    General_Licence_-_Continuation_of_Business_Lukoil_International–June_2026Download

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  • June 18, 2026: OFAC updates 2 Venezuela GLs, issues a new one, and amends an FAQ

    The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Venezuela-related General License 5X, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After August 4, 2026;” Venezuela-related General License 24A, “Certain Transactions Involving the Government of Venezuela Related to Telecommunications and Mail Authorized;” and Venezuela-related General License 59, “Authorizing the Supply of Certain Items and Services Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A. (Conviasa).”

    Additionally, OFAC is amending one Venezuela-related Frequently Asked Question, FAQ 595.

    New versions: GL 5X:

    venezuela_gl5xDownload

    and GL 24A:

    venezuela_gl24aDownload

    And new GL 59:

    venezuela_gl59Download

    And here’s the amended FAQ:

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

    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 5X on June 18, 2026, which further delays the effectiveness of the authorization in GL 5 until August 4, 2026. Between October 24, 2019 and August 4, 2026 (the date the authorization in General License 5X 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: June 18, 2026

    Updated on Jun 18, 2026

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