On July 23, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that its Licensing Hotline is moving to a new online platform dedicated to handling communications regarding the submission and processing of OFAC specific license applications.

Previously, applicants needed to call OFAC for licensing inquiries, a process that was often difficult and time-consuming. Now, these inquiries can be submitted more efficiently using an online form available on the new platform. OFAC will complete the transition to this online system on August 29, 2025. After that date, the Licensing Hotline phone line will be permanently discontinued.

In addition, OFAC has released a Quick Reference Guide: OFAC License Applications. The guide outlines the main stages of the license application process and the corresponding status updates: (1) Submission, (2) Review, and (3) Outcome.

Phase I: Submission

Once an OFAC specific license application is submitted, it is initially assigned the status “RECEIVED.” This indicates that OFAC has received the application but has not yet assigned it to a specific officer for review. Importantly, you cannot check the application’s status immediately after submission. At that stage, you are required to assign a temporary reference number to your application, which can be used for identification purposes until OFAC issues an official Case Number. Only after a Case Number is assigned you can track the status of your application via OFAC’s online portal.

Previously, it could take six months or more for a Case Number to be issued. However, over the last 2-3 months, OFAC has significantly improved processing times, assigning Case Numbers within just two to three days of submission in many cases. This accelerated timeline has helped shorten the overall license review process.

Phase II: Review

This stage includes the following possible status updates:

1. “IN PROGRESS”: This means that OFAC has begun reviewing the case.
2. “PENDING WITH APPLICANT”: The OFAC specific license application has been returned to the applicant with a request for additional information.
3. “PENDING INTERAGENCY REVIEW”: OFAC has referred the application to another federal agency for review or input.
4. “PENDING TREASURY COORDINATION”: The OFAC Licensing Division has requested input from another office within OFAC or from another division of the U.S. Department of the Treasury.
5. “PENDING MANAGEMENT REVIEW”: The case is under review by OFAC senior management.

However, the presence of these detailed status categories does not mean that every application will go through all of them. In fact, it is quite common for an OFAC specific license application to remain at the “IN PROGRESS” stage with no further status updates until a final decision is issued.

Phase III: Outcome

At the third and final stage, the following status outcomes are possible:

1. “APPROVED”: OFAC has approved the license application (or an amendment, extension, or other related request).
2. “DENIED”: The OFAC specific license application has been denied (including requests for amendments, extensions, etc.).
3. “CLOSED”: The license case has been closed. This typically occurs when a duplicate application is submitted for the same matter, when a license is deemed invalid, or when it is revoked.
4. “GUIDANCE ISSUED”: The applicant has received formal guidance from OFAC on the substance of the inquiry. This usually applies to requests for clarification of a specific issue, situation, or regulatory provision submitted through OFAC’s licensing portal.
5. “RETURNED WITHOUT ACTION”: OFAC has returned the license application without taking action and has sent a letter to the applicant explaining the reasons for this decision.

Conclusion

As noted above, after you submit an OFAC specific license application, you should not assume that it will go through all, or even most, of the status stages described earlier. In practice, the process often unfolds differently. In most cases, after submission, your application receives the status “IN PROGRESS,” where it may remain until a final decision is made. Occasionally, its status may change to one of the four options from the second phase (items 2-5), after which it typically returns to “IN PROGRESS” until OFAC issues a decision on the case.

At any point during the review, however, OFAC may request additional documents or information from the applicant. This is especially common when the applicant is a company, organization, or other legal entity. In such cases, extra care is warranted. If the request includes a broad list of documents covering an extended time period, it may signal that OFAC has already initiated an investigation into the organization’s activities for potential sanctions violations.

In this situation, it is highly advisable to seek guidance from an experienced OFAC lawyer to accurately assess the circumstances and ensure that further communication with OFAC is handled through legal counsel. Do not underestimate the seriousness of this stage.
A request for additional information during the license review process can be the functional equivalent of receiving an OFAC subpoena. In such cases, OFAC likely has substantial reasons to suspect that your company may have violated U.S. sanctions. With the help of your attorney, it will then be your responsibility to demonstrate that no violation occurred and that your organization is fully compliant with U.S. sanctions regulations.