Frequently Asked Questions

35. Do all OFAC programs involve blocking transactions?

35 … No. OFAC regulations are tailored to further the requirements and purposes of specific Executive Orders or statutes which provide the basic outline of each program. In some cases, the President has determined that a comprehensive asset freeze is appropriate, and in others the President has… Read more

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

49. If I reject or block a transaction, when do I have to report the action to OFAC? How do I submit the report?

49 … 31 C.F.R. Parts §§ 501.603 and 501.604 require blocking and reject reports to be submitted to OFAC within 10 business days of the date of the action. Optional reporting forms are available at this link and complete information may be emailed to OFAC’s Sanctions Compliance and Evaluation… Read more

50. Is there a requirement for annual reporting of blocked property? Is there a required format?

50 … Yes. A report of blocked property is to be submitted annually by September 30 to OFAC Compliance, Department of the Treasury, Washington, D.C., 20220. The standardized form can be accessed by visiting this link . If you wish to use a different format, please contact the OFAC Compliance hotline… 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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence