Frequently Asked Questions

589. Will foreign persons be subject to sanctions under CAATSA for engaging in activity with GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest?

Answer

As described in FAQs 542, 545, 574, and 579, a transaction will not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES, as amended by section 228 of CAATSA, and section 5 of UFSA, as amended by section 226 of CAATSA, if a U.S. person would not require a specific license from OFAC to participate in such a transaction.  Therefore, activity authorized by General License 15I, and occurring within the time period authorized by General License 15I, would not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES, as amended by CAATSA, or section 5 of UFSA, as amended by CAATSA.

Date Released
July 22, 2020