If you have blocked and reported property due to mistaken identity or typographical or similar errors, you may unblock such property and file an unblocking report with OFAC consistent with the procedures described in 31 CFR 501.603(b)(3). With respect to the information described in 31 CFR 501.603(b)(3)(ii)(F), the reporting person can cite FAQ 1196 in their unblocking report to indicate that the property was released due to mistaken identity or typographical errors, rather than an OFAC authorization like a general or specific license. Please note, unblocking property in which a blocked person does in fact have an interest without authorization from OFAC could expose U.S. persons to civil penalties.
Alternatively, you may seek to have such property unblocked pursuant to the administrative procedures detailed at 31 CFR 501.806, known as a "Compliance Release."
OFAC strongly encourages organizations subject to U.S. jurisdiction to develop risk-based sanctions compliance programs that allow for the proper evaluation and adjudication of potential name matches to blocked persons. Organizations should not use the Compliance Release process as a substitute for internal controls to mitigate the risk of transactions or dealings in blocked property.
Organizations should not request a Compliance Release in situations in which property was correctly blocked, but the status of the property has subsequently changed (e.g., a change in the portion of ownership by a blocked person). In such scenarios, organizations should apply for a specific license. The Compliance Release process is solely for cases of mistaken identity or typographical or similar error, in which there was never a blockable interest in the subject property (e.g., a name match to a blocked person that the reporting organization later determines, with reliable supporting evidence, to be a false positive). Please note neither a specific license nor a Compliance Release is required to unblock property when a person is delisted from the Specially Designated Nationals and Blocked Persons List.
The Compliance Release process is only available to the organization who blocked the property; thus, if a financial institution or other organization has blocked your property and you are requesting that the property be unblocked, you should engage directly with the financial institution or other organization that blocked your property in cases of mistaken identity or apply for a specific license.
Organizations must retain records as related to the transactions described above. See 31 CFR 501.601 and 31 CFR 501.602 of the Reporting, Procedures and Penalties Regulations for applicable recordkeeping and reporting requirements.