OFAC License for Inheritance: When an Heir Needs One
The three configurations that turn an estate into a sanctions matter
An OFAC license for inheritance is needed far less often than clients fear. There is no general embargo on dealings with Russia by US persons, and most cross-border estates close without a single filing in Washington. The procedural side of those files, like deadlines, powers of attorney, currency control, and bank...
New OFAC Reconsideration Portal: What Has Actually Changed
What OFAC Launched on June 29, 2026
On June 29, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) launched a new online tool for submitting requests to be removed from its sanctions lists: the OFAC Reconsideration Portal. The portal replaces the previous practice under which petitioners submitted delisting petitions by email and then went through repeated...
OFAC Removes Turkish Sanctions Evasion Network from Russia-Related SDN List
What Happened on June 29, 2026
On June 29, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) removed seven entries from the Specially Designated Nationals and Blocked Persons List (SDN List) under the RUSSIA-EO14024 program. All seven are Turkish companies and individuals previously designated for supporting Russia's military-industrial base through sanctions...
What the June 2026 OFAC Delisting of Three Russian Nationals Means
What Happened on June 23, 2026
On June 23, 2026, the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury published an update to its Specially Designated Nationals and Blocked Persons List (SDN List) that removed three Russian nationals: Anton Alekseevich Krugovov, Tamara Aleksandrovna Topchi, and Natalya Vladislavovna Puzyrnikova. All three had been designated under...
OFAC License Application Mistakes and How to Fix Them with an Amendment
OFAC’s Formal Requirements: Few Rules, But No Reason to Relax
The Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) does not impose rigid procedural requirements on the form of an OFAC specific license application. The regulatory framework, primarily 31 C.F.R. § 501.801, provides only general guidance: describe the nature of the request, identify the parties...
OFAC Blocked Wire Transfer: How to Recover Your Funds Through a Specific License
An OFAC blocked wire transfer puts both the sender and the recipient in a difficult legal position. The block itself is not final, U.S. sanctions law provides a mechanism for releasing funds: the OFAC specific license. Obtaining one, however, requires a carefully constructed legal position, and the quality of that position often determines the outcome.
This article walks through the process...
OFAC License Delay: How to Speed Up the Process
Obtaining a license from the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is one of the primary tools for authorizing transactions that would otherwise be prohibited under U.S. sanctions law. OFAC licenses may be required to unblock frozen assets, complete contracts, pay legal fees, sell property, or carry out other transactions involving sanctioned persons or...
Can You Obtain the OFAC Administrative Record Without Filing Suit?
Access to the case file, known in U.S. administrative practice as the administrative record, is one of the key questions in sanctions practice. The answer determines whether a designated party can build a focused legal position or must work blind, with only the agency’s general formulations to react to. The practical answer is short: the OFAC administrative record becomes available to a...
Lawsuit Against OFAC: Why the District of Columbia Is the Forum
Lawsuit against OFAC: where these cases are heard
When a client is added to the SDN list and then denied delisting by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), or refused an OFAC specific license, the question eventually arises: can OFAC’s decision be challenged in court, and if so, where? A lawsuit against OFAC is available, and in the overwhelming...
When You Need to Apply for an OFAC License?
Introduction
An OFAC license may be either a General License or a Specific License. General Licenses are issued by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury on its initiative, as part of its mandate to implement and enforce U.S. sanctions policy.
This article focuses on OFAC Specific Licenses. Any individual or legal entity may apply for an OFAC...