In those sanctions programs with blocking authorities, OFAC's regulations block all "property" or "interests in property" in which a blocked person has an interest. The term "property" is very broadly defined, including present, future, or contingent interests. (For more information, see FAQ 9 .)… Read more
In the case of certain sanctions programs, a transaction may be prohibited for U.S. persons, but there may be no blockable interest (i.e., no interest of a Specially Designated National (SDN), blocked government, or other blocked person) in the transaction. In this situation, the transaction should… Read more
Once it is determined that funds need to be blocked, the funds must be placed into a segregated, interest-bearing account on a U.S. financial institution's books, from which only OFAC-authorized debits may be made. The holder of the blocked funds must then report the funds as blocked property to… Read more
No. Each OFAC sanctions program is based on different underlying authorities and foreign policy and national security goals, so the prohibitions imposed vary between programs. Most programs block the property and interests in property of specific individuals and entities. Certain programs do not… Read more
Generally, yes. Most OFAC regulations contain licenses allowing a U.S. financial institution to debit blocked accounts for normal service charges, which are described within the relevant OFAC implementing regulations for each sanctions programs. The service charges must be normal, for example, in… Read more
OFAC regulations require that blocked funds earn interest at a commercially reasonable rate, i.e., at a rate currently offered to other depositors on deposits or instruments of comparable size and maturity. Date Updated: October 26, …
The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity… Read more