Frequently Asked Questions

6. Where can I find specific details about a particular sanctions program?

6 … References to relevant statutes, executive orders, regulations, guidance, general licenses, and sanctions actions for each sanctions program may be found in the Sanctions Programs and Country Information page on OFAC’s website. The OFAC Legal Library page on OFAC’s website also contains links… Read more

7. If I want to engage in a transaction or activity prohibited by OFAC, how can I do so? Can I rely on a general or specific license to engage in a transaction involving a sanctioned jurisdiction or person?

7 … OFAC issues general licenses to authorize certain transactions that would otherwise be prohibited pursuant to a particular sanctions program. These general licenses are self-executing, meaning they allow persons to engage in certain transactions involving the United States or U.S. persons… Read more

9. What does OFAC mean when it refers to "blocked" property? How does OFAC define “property”?

9 … "Blocking" refers to freezing assets or other property. Blocking immediately imposes an across-the-board prohibition against transfers or dealings of any kind with regard to the property. OFAC authorities may require U.S. persons to block all property and interests in property of certain… Read more

10. What jurisdictions or countries are sanctioned by the United States?

10 … OFAC implements, administers, and enforces U.S. sanctions across many jurisdictions. Some of these sanctions are comprehensive in nature and broadly prohibit most transactions involving the particular jurisdiction and may also include blocking restrictions on the government of such… Read more

44. Is there a dollar limit on which transactions are subject to OFAC regulations?

44 … There is no minimum or maximum amount subject to the regulations. … Is there a dollar limit on which transactions are subject to OFAC regulations? …

45. Does my bank need to check the OFAC list when selling cashier's checks and money orders? In the case of cashier's checks, do I need to check both the purchaser and the payee? As a mortgage lender, do I need to check both the purchaser and the seller's name against the Specially Designated Nationals list? Do I need to check their names against all of OFAC's other sanctions lists?

45 … Every transaction that a U.S. financial institution engages in is subject to OFAC regulations. If a bank knows or has reason to know that a target is party to a transaction, the bank's processing of the transaction would be unlawful. … Does my bank need to check the OFAC list when selling… Read more

46. If a loan meets underwriting standards but is a true "hit" on OFAC's Specially Designated Nationals (SDN) list, what do we use as a denial reason on the adverse action notice?

46 … If you have confirmed with OFAC that you have a "good hit" on the SDN list or one of OFAC's other sanctions lists , there is no reason not to explain that to the customer. The customer can contact OFAC directly for further information. … If a loan meets underwriting standards but is a true "… Read more

47. Through corporate giving programs, many banks contribute toward charities and other non-profits. To what extent does a bank need to review the recipients of these gifts or the principals of the charities?

47 … Donations to charitable institutions must be handled as any other financial transaction. The donating bank or institution should crosscheck the recipient names against OFAC's sanctions lists and assure that the donations are in compliance with OFAC sanctions programs . … Through corporate… Read more

52. Can U.S. financial institutions open correspondent accounts for Iraqi financial institutions, or process funds transfers to and from Iraqi financial institutions?

52 … Yes, U.S. financial institutions are authorized to open correspondent accounts for, and process funds transfer to or on behalf of Iraqi financial institutions. … Can U.S. financial institutions open correspondent accounts for Iraqi financial institutions, or process funds transfers to and from… Read more

95. Does a financial institution have the obligation to screen account beneficiaries for compliance with OFAC regulations?

95 … "Property," as defined in OFAC regulations, includes most products that financial institutions offer to their clients. "Property interest," as defined by OFAC, includes any interest whatsoever, direct or indirect, present, future or contingent. Given these definitions and as a matter of sound… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence