1182. Are foreign financial institutions (FFIs) subject to sanctions risk for providing all financial services involving persons blocked pursuant to Executive Order (E.O.) 14024, as amended? What about agricultural, medical, and other transactions authorized by OFAC General Licenses?
Treasury remains focused on counteracting activity that involves sanctions evasion or third-country support to Russia’s military-industrial base. At the same time, legitimate humanitarian activity and agricultural and medical trade are not the target of our sanctions. Accordingly, FFIs may continue to conduct or facilitate any transaction(s) or provide any service related to activities that are otherwise authorized or exempted under the Russian Harmful Foreign Activities Sanctions program. Foreign persons do not risk the imposition of sanctions for engaging in transactions authorized for U.S. persons under General Licenses issued under the Russian Harmful Foreign Activities Sanctions program.
FFIs may continue to rely on Treasury’s existing authorizations in...
1) This FAQ was issued in connection with OFAC’s expansion, via guidance, of the secondary sanctions provision applicable with respect to Russia through EO 14114.
OFAC expanded the EO 14114 FFI-based secondary sanctions provision such that what is sanctionable (subject to this FAQ) is having “conducted or facilitated any significant transaction or transactions, or provided any service, involving:
• Any person blocked pursuant to EO 14024 for any reason;
• The “any person operating in the technology, defense and related materiel, construction, aerospace, and manufacturing sectors of the Russian Federation economy,” and to the extent not described in this bullet’
• “individuals and entities that support the sale, supply, or transfer, directly or indirectly, of critical items identified in determinations pursuant to subsection 11(a)(ii) of E.O....