Frequently Asked Questions

36. I understand blocking a transaction, but what is meant by rejecting a transaction? When should a transaction be rejected rather than blocked?

36 … In some cases, an underlying transaction may be prohibited, but there is no blockable interest (i.e., that of a Specially Designated National (SDN) or blocked person or government) in the transaction. In these cases, the transaction is simply rejected, or not processed and returned to the… Read more

39. What do I do if I have a blocked account that needs to be escheated to the state?

39 … You need to discuss this with your state authorities and with OFAC. Updated on April 20, 2022 … What do I do if I have a blocked account that needs to be escheated to the state? …

41. Should an institution tell its customer that it blocked their funds, and, if so, how does the institution explain it to them?

41 … An institution may notify its customer that it has blocked funds in accordance with OFAC's instructions. The customer has the right to apply for the unblocking and release of the funds. To apply online to have the funds released, please go to our online application page . … Should an… Read more

42. What do I do if a person tries to open an account and the individual or entity’s name is on OFAC’s SDN List (or is otherwise a blocked person)? Do I open the account and then block the funds?

42 … A U.S. financial institution, its foreign branches, and — in some cases — its wholly-owned or -controlled foreign subsidiaries, cannot open an account for a person named on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) or a person who is otherwise blocked (e.g.,… Read more

48. I just received an interdiction "alert." What do I do?

48 … When your interdiction software or account holder checking service shows a potential match, OFAC recommends that you do an initial analysis prior to contacting OFAC. If you have a reasonably close match to a name on the Specially Designated Nationals (SDN) list (or one of OFAC's other… Read more

53. How do I differentiate between an "inquiry" and a "payment instruction" when a customer wants to send a wire transfer to a sanctioned party or country?

53 … In those programs with blocking provisions, OFAC's regulations block all "property" in which a target has an interest. The term "property" is very broadly defined, including present, future or contingent interests. In the case of a wire transfer, the bank will be holding blocked property upon… Read more

72. Can I send money to a sanctioned country using a third-country company’s website? Can I buy gifts for someone in a sanctioned country over the internet? The websites tell me that it’s ok because they themselves are not sanctioned parties.

72 … You cannot do something indirectly that you would not be able to do directly. Therefore, these sites can be used to facilitate authorized transactions, but you cannot use them to perform a transaction which would be in violation of U.S. law. For example, the Cuban Assets Control Regulations (… Read more

73. My company provides money remittance and account services via the Internet. Does OFAC have any compliance guidance for this type of business?

73 … Complying with United States sanctions policy presents unique challenges to institutions that operate exclusively on the Internet. The Internet has often been thought of as an "anonymous venue" in that e-commerce transactions can be conducted in relative privacy with little or no face-to-face… Read more

434. Are all applications designed to run on mobile operating systems (“apps”) covered by 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?

434 … The exportation to Iran of apps that are designated EAR99 or classified under export control classification number (ECCN) 5D992.c, as specified in category (8) of the 31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications, is authorized under 31 CFR § 560.540(a)(… Read more

435. Is the exportation of anti-virus, anti-malware, anti-tracking, and anti-censorship software authorized under 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?

435 … Yes. Section 560.540(a)(3) authorizes the exportation of certain anti-virus, anti-malware, anti-tracking, anti-censorship software, and related services, as specified in categories (6), (7), and (9) of the31 CFR § 560.540 List of Services, Software, and Hardware Incident to Communications.… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence