On 19 October 2026, the US Treasury's Office of Foreign Assets Control announced designations under the Protecting American Intellectual Property Act of 2022, added entities to its Non-SDN Menu-Based Sanctions List and issued General Licences 1 and 2. The list action and the two licences have different effects and must be read separately.
General Licence 1
General Licence 1 addresses the interaction between PAIPA and the Cyber-Related Sanctions Regulations. Subject to paragraph (b), it authorises transactions prohibited by PAIPA only to the extent those transactions are authorised or exempt under the Cyber-Related Sanctions Regulations, including under a relevant general or specific licence.
This is a bounded authorisation. Paragraph (b) states that General Licence 1 does not authorise a transaction otherwise prohibited by PAIPA or another part of 31 CFR chapter V unless it is separately authorised. The licence also states that other federal laws and other agencies' requirements continue to apply.
General Licence 1 should therefore not be described as overriding PAIPA or as a general permission for dealings with a listed entity.
General Licence 2 and the wind-down period
General Licence 2 provides a time-limited wind-down authorisation. Subject to paragraph (b), it covers transactions prohibited by PAIPA that are ordinarily incident and necessary to wind down transactions involving the four entities named in the licence. It also covers an entity in which one or more of those named entities owns, directly or indirectly, individually or in aggregate, a 50 per cent or greater interest.
The authorisation runs through 12:01 a.m. eastern standard time on 19 January 2027. Any payment to a person subject to PAIPA blocking prohibitions must be made into a blocked account located in the United States.
Paragraph (b) retains important limits. It does not authorise other PAIPA-prohibited transactions outside paragraph (a), or activity prohibited by another part of 31 CFR chapter V, unless separately authorised. As with General Licence 1, other federal laws and agency requirements remain applicable.
What the list action means
OFAC's list entries apply a range of measures to the named entities. The published measures include blocking, restrictions on certain loans or credit, foreign-exchange prohibitions, restrictions on transfers of credit or payments involving financial institutions, and limits on certain equity or debt investment. The precise measure and exception must be read from the current list entry rather than inferred from the fact of listing alone.
The announcement combines a list action with two different licences. General Licence 1 depends on what is authorised or exempt under the Cyber-Related Sanctions Regulations. General Licence 2 is limited by purpose, named entities and ownership scope, timing, the blocked-account condition and its paragraph (b) exclusions.
Before considering a payment or wind-down activity, a firm would need the current OFAC list and operative licence text, the parties and ownership involved, the relevant US-jurisdiction nexus and the complete transaction facts. Other sanctions authorities may also apply.
Status and limitations
OFAC published the list action and dated both general licences 19 October 2026. Sanctions designations and licences can be amended, superseded or revoked, so current official material should be checked before reliance.
This article does not determine that any payment, counterparty or wind-down activity is authorised. It does not state or imply that any AnyAccount customer, prospect or transaction involves a listed person. It provides general information and is not legal advice.