Frequently Asked Questions

499. What type of research exceeds the scope of the Compliance Services Guidance?

499 … A U.S. person may not conduct research that otherwise involves the importation or exportation of services where such transactions are prohibited by any part of 31 C.F.R. chapter V, unless such transactions are authorized by OFAC. … What type of research exceeds the scope of the Compliance… Read more

116. On February 14, 2008, OFAC issued guidance stating that the property and interests in property of an entity are blocked if the entity is owned, directly or indirectly, 50% or more by a person whose property and interests in property are blocked pursuant to an Executive Order or regulations administered by OFAC. We act as an intermediary bank in wire transfers between other banks. Does OFAC expect banks that are acting as financial intermediaries to research non-account parties that do not appear on the SDN List, but are involved with or referenced in transactions that are processed on behalf of correspondents?

116 … A wire transfer in which an entity has an interest is blocked property if the entity is 50% or more owned by a person whose property and interests in property are blocked. This is true even in instances where such a transaction is passing through a U.S. bank that (1) is operating solely as an… Read more

5. How do I determine if I have a valid OFAC match?

5 … If you are calling about a wire transfer or other "live" transaction: Step 1. Is the "hit" or "match" against OFAC's Specially Designated Nationals (SDN) list, one of its other sanctions lists, or targeted countries, or is it "hitting" for some other reason (i.e., "Control List" or "PEP," "CIA… Read more

25. Does OFAC itself require that banks set up a certain type of compliance program?

25 … No. There is no single compliance program suitable for every financial institution. OFAC is not itself a bank regulator; its basic requirement is that financial institutions not violate the laws that it administers. Financial institutions should check with their regulators regarding the… Read more

1. What is OFAC and what does it do?

1 … The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions against targeted foreign jurisdictions and regimes, as well as individuals and entities engaging in harmful activity, such as terrorists, international narcotics… Read more

3. What kinds of prohibitions does OFAC impose?

3 … Each OFAC sanctions program is based on different foreign policy and national security goals, so the prohibitions imposed may vary between programs. Many sanctions programs require blocking the property and interests in property of specific individuals and entities and prohibit dealing in such… Read more

4. Are there exceptions to sanctions prohibitions? Are exceptions the same across sanctions programs?

4 … Yes. There may be exceptions to sanctions prohibitions. Exceptions may take the form of authorizations, such as general licenses and specific licenses, or exemptions. OFAC issues general licenses in most of its sanctions programs to authorize certain transactions that would otherwise be… Read more

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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence