583. Why is OFAC issuing General License 12B, and what new activity does it authorize?

OFAC issued General License 12B to address difficulties blocked U.S. persons are having accessing funds needed for authorized wind-down and maintenance activities. General License 12B explicitly permits originating and intermediary U.S. financial institutions to process funds transfers that they would otherwise block to an account held by a blocked U.S. person at a U.S. financial institution. In addition, General License 12B clarifies that U.S. financial institutions can release such funds for authorized maintenance and wind-down purposes only. On May 22, 2018, OFAC issued amended General License 12C to make conforming edits in light of the issuance of General License 15.