No. Non-U.S. persons may engage in or facilitate transactions that would be authorized for U.S. persons under GLs 14 or 15 without exposure to sanctions under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended.
For example, activity that would be authorized by GLs 14 or 15 if engaged in by a U.S. person would not be considered “significant” for the purposes of a secondary sanctions determination under E.O. 13224, as amended. Accordingly, foreign financial institutions do not risk exposure to correspondent and payable-through account sanctions under E.O. 13224, as amended, if they knowingly conduct or facilitate a transaction on behalf of persons blocked under E.O. 13224, as amended, that would be authorized under GLs 14 or 15 if engaged in by a U.S. person.
If individuals, entities, companies, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they can contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov. Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490.