Frequently Asked Questions

29 … There is no prepackaged compliance program that fits the needs of every bank. Banks, obviously, range in size from small to some of the largest institutions in the world. A good starting point is to go to the OFAC website and look under " Regulations by Industry ." Then read the brochure for… Read more

30 … The following information will provide you with areas to consider as you review your OFAC procedures . … How do I know if my compliance program is adequate? …

31 … There are a wide variety of software packages available to the financial community. The size and needs of each institution help to determine what to look for in a package. Some packages are used to interdict sanctioned countries and names on the Specially Designated Nationals or other… Read more

32 … Once it has been determined that funds need to be blocked, they must be placed into an interest-bearing account on your books from which only OFAC-authorized debits may be made. The blocking also must be reported to OFAC Compliance within 10 business days. Some banks have opted to open… Read more

33 … OFAC regulations require that 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. … How much interest do I have to pay on the blocked …

34 … Generally yes. In most cases (excluding Iraq, for instance) OFAC regulations contain provisions to allow a bank to debit blocked accounts for normal service charges, which are described in each set of regulations. The charges must be in accordance with a published rate schedule for the type of… Read more

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 … 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 … 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 … 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