OFAC Penalty for Sanctions Violations: What Actually Reduces the Amount
The Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) does not have to prove intent. Liability attaches to the act itself: the payment cleared, the goods shipped, the account was serviced. Intent affects how much a company pays, not whether it is liable at all.
Violations also rarely look like deliberate evasion. More often they come from an ownership stake...
Usmanov and Fridman: EU Sanctions Delisting Leaves the SDN List Untouched
On 22 September 2026, hours before its own deadline, the ambassadors of the EU member states finally reached an agreement and extended Russia’s individual sanctions for three years. Part of the compromise was removing several individuals who had been under sanctions since 2022. None came off through litigation. All were traded away in a room in Brussels, which makes the decision political...
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...
OFAC 50 Percent Rule: When a Company Becomes Blocked
What the OFAC 50 percent rule actually says
The company is not on any sanctions list. The name screens clean, there are no hits, and it is registered in a perfectly ordinary jurisdiction. The transaction is still prohibited, and the payment will still be blocked. That is the OFAC 50 percent rule at work.
The statement of the rule is short. Any entity owned in the aggregate, directly or...
OFAC Investigation: The Three Documents That Decide the Penalty
How an OFAC investigation actually begins
An OFAC investigation rarely opens with anything dramatic. It opens with an administrative subpoena from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), signed by an enforcement officer. The tone is measured. The language is broad: produce information and records concerning transactions of a certain type over a certain...
How to Unblock Assets in a US Bank: A Step-by-Step Guide for Individuals
Having your funds blocked in a US bank is a serious situation. Access to the account is frozen, the money is not moving, and the bank offers little or no explanation. Faced with that uncertainty, many people who need to know how to unblock assets in a US bank attempt to resolve the matter on their own, and in doing so, make mistakes that can significantly complicate the case down the line....
Lukoil GL 131F: OFAC Extends Authorization for LIG Sale Negotiations
On May 28, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 131F (Lukoil GL 131F), replacing General License No. 131E and extending the authorization through 12:01 a.m. EDT on June 27, 2026. The license continues to authorize negotiations and the entry into contingent contracts for the sale of Lukoil International GmbH (LIG), the...
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...
Lukoil Foreign Assets Sale: GL 131E Extends the Negotiation Window to May 30, 2026
What Happened on April 29, 2026
On April 29, 2026, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued General License No. 131E (GL 131E), extending the authorization for negotiations and the execution of conditional contracts for the sale of Lukoil International GmbH (LIG), the Austrian holding company through which Lukoil manages its foreign operations. The new...