Frequently Asked Questions

567. I am a U.S. person employee or work at an office of a company that was designated under E.O. 13661 or E.O. 13662, or blocked by operation of law pursuant to OFAC’s 50 percent rule on April 6, 2018 as a result of such a designation. What am I authorized to do with respect to continuing activities of the blocked entity?

Answer

In issuing General License 12A, OFAC is authorizing a time-limited maintenance or wind down of operations, contracts, or other agreements that were in effect prior to April 6, 2018 and in which the blocked entities listed in General License 12A have an interest, provided that any payment made directly or indirectly to the blocked entities listed in General License 12A be deposited in a blocked account at a U.S. financial institution.

In general, General License 12A would authorize all transactions ordinarily incident to the continuity of operations or to facilitate a wind down, including the provision of salary payments, pension payments, or other benefits, by the blocked entities listed in General License 12A, or the provision of services by the employee to such blocked entities, until the expiry of General License 12A.

U.S. person employees are encouraged to review the applicable OFAC regulations, authorizations, and public guidance. If, after conducting that review, you are concerned that your activities as an employee are not authorized by general license, you may contact OFAC.

If you are a U.S. person employee of an individual or entity that is not among the blocked entities listed in General License 12A, including entities blocked pursuant to OFAC’s 50 percent rule, you are prohibited from engaging in transactions with such individual or entity, including the provision or receipt of goods or services, or otherwise transacting or dealing in any property in which the individual or entity has an interest. If you wish to seek authorization to maintain or wind down operations, contracts, or other agreements with such individual or entity, contact OFAC.

Date Released
April 23, 2018