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OFAC License Lawyer

Legal Assistance With OFAC Specific License Applications

Arkady Bukh Law Firm assists individuals, business owners, financial professionals and companies with applications for authorization from the U.S. Department of the Treasury’s Office of Foreign Assets Control.

An OFAC specific license may be needed when a transaction would otherwise be prohibited under a U.S. sanctions program and no applicable general license, exemption or other authorization is available.

Legal assistance may include:

  • Determining whether an OFAC license is required
  • Reviewing applicable general licenses and exemptions
  • Preparing specific license applications
  • Requesting the release of blocked funds
  • Identifying the correct sanctions program
  • Preparing supporting documents
  • Explaining transaction routes and ownership
  • Responding to OFAC requests for additional information
  • Monitoring delayed applications
  • Updating pending applications when circumstances change
  • Reviewing approved license conditions
  • Requesting amendments, renewals or extensions
  • Evaluating denied applications
  • Preparing a reconsideration request based on new information or changed circumstances
  • Coordinating OFAC authorization with banking, export-control and other regulatory requirements

Submitting a license application does not itself authorize the proposed transaction. Unless another authorization applies, the parties should not proceed until OFAC issues a license covering the relevant activity.

Who This OFAC License Lawyer Represents

Arkady Bukh Law Firm assists:

  • Individuals seeking access to blocked funds
  • Owners of restricted bank accounts
  • S. citizens and permanent residents
  • Foreign nationals
  • Russian individuals and companies
  • International businesses
  • Importers and exporters
  • Banks and financial professionals
  • Investors
  • Corporate executives
  • Professional-service providers
  • Cryptocurrency companies
  • Technology businesses
  • Shipping and logistics companies
  • Beneficiaries of estates and trusts
  • Parties to contracts involving blocked persons
  • Businesses seeking to complete or wind down restricted transactions
  • Clients whose earlier license applications were delayed, returned or denied

The need for a license depends on the transaction and applicable legal authority, not solely on the nationality of the applicant or counterparty.

A foreign person may require OFAC authorization when property is held by a U.S. bank, a payment passes through the United States, a U.S. person must participate or blocked property is involved.

What Is an OFAC License?

An OFAC license is an authorization to engage in activity that would otherwise be prohibited under an OFAC-administered sanctions program.

There are two principal types of OFAC licenses:

  • General licenses
  • Specific licenses

A license does not remove every legal restriction that may apply to a transaction. Separate requirements may arise under banking, export-control, customs, tax, securities or other laws.

The scope of an OFAC authorization should be read carefully. A license may be limited by:

  • The authorized persons
  • The named counterparties
  • The property involved
  • The purpose of the transaction
  • The permitted amount
  • The payment route
  • The effective period
  • Reporting requirements
  • Recordkeeping requirements
  • Conditions imposed by OFAC
  • Activities expressly excluded from the authorization

Conduct outside those terms may remain prohibited.

General Licenses

A general license authorizes a defined category of transactions for all persons who satisfy its conditions. A qualifying person does not submit an individual license application merely to receive the benefit of the general authorization.

General licenses may cover limited categories of activity involving:

  • Legal services
  • Telecommunications
  • Personal communications
  • Humanitarian transactions
  • Agricultural products
  • Medicine and medical devices
  • Personal remittances
  • Diplomatic activity
  • Wind-down transactions
  • Certain payments
  • Particular organizations or sectors
  • Limited dealings with blocked property

The precise language of the general license controls.

Before relying on a general license, the parties should determine:

  • Whether it applies to the correct sanctions program
  • Whether all parties fall within its scope
  • Whether the transaction is of an authorized type
  • Whether the license is currently effective
  • Whether it has an expiration date
  • Whether blocked property is involved
  • Whether another prohibition remains applicable
  • Whether reporting is required
  • Whether records must be maintained
  • Whether an entity is blocked under OFAC’s 50 Percent Rule

A general license should not be treated as a broad exception to all U.S. sanctions.

OFAC advises applicants not to file a specific license application solely to notify the agency of activity that is already fully authorized by a general license.

Specific Licenses

A specific license is written authorization issued by OFAC to a particular person or entity in response to an application.

It may authorize:

  • One transaction
  • Several related transactions
  • Activity during a defined period
  • Dealings with specified property
  • Payments involving identified parties
  • Release of blocked funds
  • Administration of blocked property
  • Particular legal or professional services
  • A limited wind-down process
  • Other conduct described in the license

A specific license is not necessarily limited to one payment. Its scope depends on the application, applicable licensing policy and authorization issued by OFAC.

The applicant must comply strictly with the final license. Approval of one transaction does not automatically authorize related transactions, additional counterparties or later activity outside the stated terms.

When a Specific License May Be Needed

A specific license may be considered when:

  • A bank has blocked a payment
  • Funds are held in a blocked account
  • A transaction involves property in which an SDN has an interest
  • A contract requires payment to or from a blocked party
  • A person needs to receive funds from a restricted source
  • A company needs to make a payment that is otherwise prohibited
  • A U.S. person must provide services to a blocked person
  • An estate or trust includes blocked assets
  • A business needs to complete a limited wind-down
  • A general license does not cover every part of the proposed transaction
  • A general license has expired
  • A foreign transaction requires the participation of a U.S. bank or person
  • A sanctions program contains a favorable or stated licensing policy
  • OFAC authorization is required to administer, transfer or release property

Not every transaction involving a sanctioned country or foreign person requires a specific license.

The initial legal review should determine whether the transaction is:

  • Prohibited
  • Fully authorized by a general license
  • Covered by an exemption
  • Outside OFAC’s jurisdiction
  • Subject to a narrower non-blocking restriction
  • Eligible for specific licensing
  • Also subject to another agency’s authorization

OFAC License Application Process

Step 1 — Identify the Proposed Transaction

The application should begin with a clear description of what the applicant seeks permission to do.

The review should identify:

  • The applicant
  • Every counterparty
  • The ultimate beneficiary
  • The property or services involved
  • The amount and currency
  • The source of funds
  • The destination of funds
  • The banks and payment processors
  • The expected payment route
  • The proposed dates
  • The commercial, personal, legal or humanitarian purpose

A vague request for permission to “do business” with a sanctioned party is generally less useful than a defined request supported by a complete transaction structure.

Step 2 — Identify the Sanctions Program

Different sanctions programs contain different prohibitions, exemptions, general licenses and licensing policies.

The analysis should identify:

  • The applicable regulations
  • Relevant executive orders
  • Statutory authorities
  • OFAC directives
  • General licenses
  • Frequently asked questions
  • Program-specific licensing guidance
  • The sanctions-list status of each party
  • Ownership by blocked persons
  • Restrictions applicable on the proposed transaction date

The application should explain why the transaction is prohibited or may require authorization.

Step 3 — Determine Whether Existing Authorization Applies

Before preparing a specific license application, counsel should review whether the transaction is already authorized by:

  • A general license
  • A regulatory exemption
  • A statutory exemption
  • A previously issued specific license
  • A wind-down authorization
  • A humanitarian authorization
  • Another applicable OFAC provision

The application may need to explain why a potentially relevant general license does not fully cover the proposed activity.

For example, a general license may authorize one party or service but not:

  • The proposed payment route
  • A particular blocked bank
  • An additional counterparty
  • A transaction after the license expires
  • A form of financing
  • The release of already blocked property
  • Another service connected with the transaction

Step 4 — Review Ownership and Sanctions-List Status

The application should accurately identify the ownership of participating companies.

Under OFAC’s 50 Percent Rule, an entity may be treated as blocked even when its name does not appear on the SDN List if one or more blocked persons own at least 50 percent of it in the aggregate, directly or indirectly.

The ownership review may include:

  • Direct shareholders
  • Parent companies
  • Intermediate holding companies
  • Beneficial owners
  • Trusts
  • Nominee owners
  • Aggregated interests of several blocked persons
  • Changes in ownership
  • Transfers made after designation
  • The role of sanctioned directors or executives

The application should not state that a company is non-sanctioned merely because its name was not found in a list search.

Step 5 — Collect Supporting Documents

OFAC recommends submitting relevant supporting documentation with the application.

Depending on the matter, supporting documents may include:

  • Passports and identity documents
  • Corporate registration records
  • Ownership charts
  • Shareholder records
  • Contracts
  • Invoices
  • Purchase orders
  • Bank statements
  • Payment instructions
  • SWIFT or other payment messages
  • Correspondence with the blocking bank
  • Source-of-funds records
  • Evidence of the ultimate beneficiary
  • Court orders
  • Estate and trust documents
  • Medical records
  • Humanitarian documents
  • Shipping records
  • Product descriptions
  • Prior licenses
  • Communications with government agencies
  • Evidence concerning the purpose of the transaction

Documents written in another language should generally be accompanied by an accurate English translation.

A large collection of documents without an explanation may be less effective than an organized submission connecting each exhibit to the relevant fact.

Step 6 — Prepare the Legal and Factual Narrative

A specific license application should provide a detailed and fact-focused explanation of the request.

The narrative may address:

  • Who the applicant is
  • What authorization is requested
  • Why the transaction is currently prohibited
  • Which parties are involved
  • The ownership of each entity
  • How the transaction will be performed
  • How money will move
  • Why the activity is consistent with the relevant licensing policy
  • Why a general license does not apply
  • Whether property is already blocked
  • Whether other agencies have been contacted
  • Whether a court or contractual deadline applies
  • What safeguards will be used
  • What reports the applicant is prepared to provide

OFAC’s application guidance recommends considering a cover letter containing a complete narrative.

Material information should not be omitted merely because it appears unfavorable. A complete and accurate explanation is important when requesting discretionary government authorization.

Step 7 — Identify Genuine Deadlines

Important dates should be stated clearly and supported by documents.

Examples may include:

  • A court-imposed deadline
  • A medical-treatment date
  • An expiring contract
  • A payment deadline
  • A deadline for administering an estate
  • Expiration of an existing license
  • A deadline imposed by another government agency

OFAC advises applicants not to assign unsupported urgency to a request.

A claim of urgency is more persuasive when the application explains the specific harm, date and reason the matter cannot wait.

Step 8 — Submit the Application Through the OFAC Portal

OFAC accepts applications for specific licenses and requests for interpretive guidance through its Licensing Portal.

The portal can be used to:

  • Submit an application
  • Request interpretive guidance
  • Save an application through a registered account
  • Review submitted applications
  • Check case status
  • Replicate an earlier application
  • Submit certain reports required by a license

Registration for an account is available but is not required for every submission. An applicant can check status using the assigned Case ID.

OFAC advises applicants not to submit specific license requests through unofficial websites or ordinary email when the Licensing Portal is the required submission method.

After submission, the applicant should preserve:

  • The complete filed application
  • Every attachment
  • The Case ID
  • The confirmation of submission
  • Later correspondence
  • Copies of additional information sent to OFAC

Applications to Release Blocked Funds

A specific license application may request authorization to release a blocked payment or account.

The application should ordinarily identify:

  • The blocking financial institution
  • The date of the block
  • The amount and currency
  • The originating party
  • The intended beneficiary
  • The payment route
  • The sanctions program involved
  • The person whose alleged interest caused the block
  • The purpose of the payment
  • The source of funds
  • The current location of the property
  • Previous communications with the bank
  • Any blocking or reference number
  • The proposed payment instructions if release is authorized

The applicant should also determine whether the problem is actually:

  • An OFAC block
  • A private compliance hold
  • A false-positive name match
  • A law-enforcement seizure
  • A civil forfeiture restraint
  • A restriction imposed by a foreign government

These situations may require different procedures.

For matters centered on frozen accounts and payments, see the OFAC Unblocking Applications Attorney page.

Legal Fees and Professional Services

Sanctions programs may contain general licenses or other rules addressing legal services, but the authorization to provide legal services does not always authorize every related payment.

Questions may include:

  • Whether a U.S. attorney may provide the service
  • Whether payment may come from blocked funds
  • Whether payment may be received from an unblocked source
  • Whether the service concerns a sanctions challenge
  • Whether prior authorization is required
  • Whether reporting applies
  • Whether another professional service is separately restricted

The legal-service authorization and payment authorization should be reviewed separately.

Estates, Trusts and Inheritances

An estate or trust matter may require OFAC authorization when:

  • A beneficiary is blocked
  • Estate property is blocked
  • A U.S. fiduciary holds an interest for a sanctioned person
  • A distribution would transfer property to a blocked person
  • A bank refuses to process an inheritance payment
  • The estate needs to sell or administer blocked property
  • Third-party beneficiaries claim an interest in restricted funds

Supporting documents may include:

  • A will
  • Trust documents
  • Probate orders
  • Letters of administration
  • Death certificates
  • Beneficiary information
  • Asset schedules
  • Bank records
  • Proposed distribution instructions

The requested authorization should distinguish between administering property and transferring the beneficial interest.

Business and Contract Transactions

A business license application may involve:

  • Payment under an existing contract
  • Completion of goods already ordered
  • Wind-down of operations
  • Sale or preservation of property
  • Professional services
  • Intellectual property
  • Insurance
  • Shipping
  • Debt repayment
  • Corporate restructuring
  • A transaction involving a blocked minority or majority owner

The application should explain:

  • When the contract was signed
  • Whether sanctions were imposed before or after the agreement
  • What performance has already occurred
  • Which obligations remain
  • Who will receive value
  • Whether blocked persons benefit
  • Why the transaction cannot be completed under a general license
  • Whether the proposal reduces or increases blocked persons’ interests
  • How funds and property will be controlled

A contract does not override sanctions. The fact that an agreement predates a designation may be relevant, but it does not automatically authorize performance.

Interpretive Guidance Instead of a License

In some matters, the primary question is not whether OFAC should authorize prohibited conduct but whether the proposed activity is prohibited at all.

The applicant may consider requesting interpretive guidance when clarification is needed concerning:

  • The application of a general license
  • Ownership under the 50 Percent Rule
  • The meaning of a regulatory provision
  • Whether particular activity falls within a prohibition
  • Whether the proposed service is authorized
  • Whether property must be blocked or a transaction rejected

A request for interpretive guidance is different from a specific license application.

Interpretive guidance does not provide discretionary authorization for conduct that OFAC concludes is prohibited. If the transaction is prohibited, a specific license may still be required.

What Happens After an Application Is Submitted?

OFAC’s review process may include several stages.

Current portal statuses may include:

  • Received — OFAC has received the application but has not yet assigned it for substantive review.
  • In Progress — OFAC has begun reviewing and evaluating the request.
  • Pending With Applicant — OFAC has sent a request for additional information.
  • Pending Treasury Coordination — another OFAC or Treasury component is reviewing the matter.
  • Pending Interagency Review — OFAC has requested input from another federal agency.
  • Pending Management Review — OFAC management is reviewing the proposed response.
  • Approved — OFAC has granted a license, amendment, renewal or extension.
  • Guidance Issued — OFAC has provided interpretive guidance.
  • Denied — OFAC has denied the application or revoked a license.
  • Returned Without Action — OFAC has returned the request with an explanatory letter.
  • Closed — the matter was closed as duplicate, void or withdrawn.

Not every application passes through every status.

The review may be iterative. An application can return to the applicant for information after interagency review or move through more than one round of coordination.

OFAC Follow-Up Requests

OFAC may request additional information before reaching a decision.

A follow-up request may concern:

  • Missing identity documents
  • Corporate ownership
  • The role of an SDN
  • The proposed payment route
  • The source and destination of funds
  • The purpose of the transaction
  • A potentially applicable general license
  • Inconsistent information
  • Another participating company
  • Communications with a bank
  • Dates and deadlines
  • The current status of blocked property
  • Other government approvals
  • Changes since the original application

The portal status may change to Pending With Applicant while OFAC waits for a response.

A response should:

  • Address every question
  • Follow OFAC’s requested format
  • Correct inaccurate prior information
  • Explain missing records
  • Include relevant supporting documents
  • Identify changes since submission
  • Be submitted within the stated period
  • Remain consistent with the original transaction history

OFAC’s published best practices advise applicants to respond promptly.

An incomplete answer may lead to another information request, delay or a decision based on an insufficient record.

Changes While the Application Is Pending

OFAC should be advised when material circumstances or contact information change.

Relevant changes may include:

  • A new counterparty
  • A change in ownership
  • A different bank
  • A revised payment route
  • A different amount
  • A change in the ultimate beneficiary
  • Expiration of a contract
  • A new sanctions designation
  • Amendment or expiration of a general license
  • Settlement of related litigation
  • Release or transfer of property outside U.S. jurisdiction
  • A change in urgency
  • New communications from another government agency

The applicant should not assume that the original request automatically covers a materially different transaction.

A change may require:

  • A supplemental submission
  • A revised application
  • Withdrawal of the original request
  • An amendment after approval
  • A new legal analysis

Delayed OFAC Applications

OFAC does not provide a universal processing time for specific license applications.

The time required may depend on:

  • Complexity of the transaction
  • Number of parties
  • Ownership questions
  • The sanctions program
  • National-security or foreign-policy considerations
  • Interagency consultation
  • Need for State or Commerce Department input
  • Volume of similar applications
  • Requests for additional information
  • Changes occurring while the request is pending

OFAC generally notifies applicants in writing when a determination has been made.

Applicants can use the Case ID to check progress through the Licensing Portal.

During a delay, the applicant should:

  • Check the official portal status
  • Respond promptly to information requests
  • Update OFAC about material changes
  • Preserve the supporting records
  • Identify new deadlines
  • Confirm that contact details remain correct
  • Review changes to sanctions regulations and general licenses
  • Avoid conducting the proposed transaction without authorization

OFAC’s best-practices guidance advises against:

  • Submitting duplicate applications merely because a decision has not been issued
  • Repeatedly contacting the assigned licensing officer for status reports
  • Claiming unsupported urgency
  • Sending the same application through several submission methods

A duplicate application may be closed rather than accelerate review.

When an Application Is Pending With the Applicant

A Pending With Applicant status generally means that OFAC has issued a request for information and is waiting for the applicant’s response.

The applicant should determine:

  • The response deadline
  • Whether every requested document is available
  • Whether translations are required
  • Whether a legal explanation is needed
  • Whether information from a bank or counterparty must be obtained
  • Whether the proposed transaction has changed
  • Whether additional time should be requested
  • Whether the answer may affect another investigation

A delayed response can prolong the review. An inaccurate response may create more serious legal problems.

Approved OFAC Licenses

An approval should be reviewed before any transaction occurs.

The license may specify:

  • Authorized licensees
  • Permitted counterparties
  • Covered property
  • Maximum amounts
  • Approved financial institutions
  • Payment routes
  • Effective and expiration dates
  • Required documents
  • Reporting obligations
  • Recordkeeping obligations
  • Prohibited related activity
  • Conditions for renewal
  • References that must appear in payment instructions

A bank or other participating institution may request a copy of the license and supporting transaction documents before processing the activity.

A license does not require a private bank to complete a transaction. Financial institutions may apply their own risk policies, contractual requirements and compliance reviews.

The licensee should retain:

  • The license
  • The original application
  • Supporting documents
  • Communications with OFAC
  • Transaction records
  • Reports submitted under the license
  • Bank correspondence
  • Evidence that every license condition was satisfied

Reports Required by a Specific License

A specific license may require reports concerning transactions conducted under the authorization.

The report may need to identify:

  • Dates
  • Amounts
  • Currency
  • Parties
  • Banks
  • Payment references
  • Property transferred
  • Services provided
  • Outstanding balances
  • Supporting documents
  • Compliance with specific conditions

The license controls the reporting obligation.

Failure to provide a required report or observe a license condition may create a compliance issue even when the underlying transaction was authorized.

Amendments to an OFAC License

An amendment may be required when the authorized transaction changes after OFAC issues the license.

Potential changes include:

  • Adding a party
  • Changing a bank
  • Changing a payment route
  • Increasing the amount
  • Extending the transaction period
  • Adding property
  • Changing the purpose of the transaction
  • Correcting identifying information
  • Revising reporting requirements

The licensee should not assume that OFAC would consider the change immaterial.

When the new activity falls outside the written terms, the licensee may need to request an amendment before proceeding.

Renewing or Extending a License

Some licenses authorize activity only through a stated date.

OFAC’s published best practices recommend submitting a renewal request approximately 60 to 90 days before expiration.

A renewal submission may include:

  • The existing license
  • Transactions completed under it
  • Reports previously submitted
  • Activity that remains unfinished
  • Updated parties and ownership information
  • The reason additional time is needed
  • Any changes in the applicable sanctions program
  • Proposed new expiration date
  • Updated supporting documents

Submitting a renewal request does not automatically extend the existing authorization. Unless OFAC grants an extension or another authorization applies, activity should stop when the license expires.

Denied OFAC License Applications

OFAC may deny a specific license application.

A denial constitutes final agency action, and OFAC regulations do not provide a formal administrative appeal process for license denials.

However, OFAC may reconsider a determination for good cause.

Possible grounds for reconsideration may include:

  • Material changed circumstances
  • New relevant evidence
  • Documents unavailable during the original review
  • A change in ownership
  • A change in the proposed transaction
  • A new or amended licensing policy
  • A new general license
  • Correction of a material factual misunderstanding
  • Removal of a problematic party
  • A revised transaction structure
  • New humanitarian or judicial circumstances

Sending the same application again without addressing the basis for denial is unlikely to create a meaningful new record.

A reconsideration request should explain:

  • The earlier Case ID
  • The date and terms of the denial
  • What has changed
  • What new information is being supplied
  • Why the new facts are material
  • Why authorization should now be granted
  • Whether the proposed transaction has been revised

A denial should also be distinguished from Returned Without Action. An application returned without action is accompanied by an explanation and may indicate that no license is needed, that another procedure is appropriate or that the request cannot be acted upon in its submitted form.

Can a Denial Be Challenged in Court?

OFAC states that a license denial is final agency action and that its regulations do not provide a formal appeal.

Whether judicial review is legally available depends on the circumstances, applicable statutes, jurisdiction, procedural history and nature of the government action.

Judicial proceedings should not be described as a routine appeal from every license denial.

Before considering litigation, the client should evaluate:

  • The stated reason for denial
  • Whether reconsideration is available
  • Whether relevant facts have changed
  • Whether another authorization exists
  • Whether the dispute concerns a license, designation, blocked property or forfeiture
  • Whether administrative remedies have been adequately developed
  • The practical effect of the transaction delay

Common Weaknesses in OFAC License Applications

An application may be delayed, returned or denied when it contains:

  • An unclear description of the requested authorization
  • Missing parties
  • Incomplete ownership information
  • No explanation of the sanctions prohibition
  • No analysis of applicable general licenses
  • Unsupported urgency
  • Missing bank or payment information
  • Missing source-of-funds evidence
  • Documents without English translation
  • Inconsistent dates or amounts
  • An unexplained change in transaction structure
  • No supporting contracts or invoices
  • A request broader than necessary
  • A request to conduct activity that another law independently prohibits
  • Duplicate applications
  • Incorrect or outdated contact information
  • Failure to respond to an OFAC information request

A well-organized application does not guarantee approval, but it can reduce avoidable questions and allow OFAC to evaluate the actual request.

OFAC Authorization and Other Agencies

OFAC may coordinate certain applications with other parts of the Treasury Department or other federal agencies.

The Department of State, Department of Commerce and other agencies may have an interest in the proposed transaction.

An OFAC license does not automatically satisfy:

  • Export Administration Regulations
  • International Traffic in Arms Regulations
  • Customs requirements
  • Banking rules
  • Money-transmitter licensing
  • Securities laws
  • Tax obligations
  • Immigration or travel requirements
  • Foreign regulatory requirements

For example, authorization under OFAC sanctions may not authorize the export or re-export of controlled goods or technology.

The applicant should identify all necessary approvals rather than treating an OFAC license as a universal government permit.

Incorrect License Categories in the Previous Page

OFAC recognizes general and specific licenses as its two principal types of license.

Terms such as the following should not be presented as universal, separate OFAC license categories:

  • Temporary license
  • Humanitarian license
  • Automatic license
  • Reporting license
  • Re-export license
  • Re-transfer license
  • Defense services license
  • D-notice license
  • Letter of credit license

A general or specific license may:

  • Have a limited duration
  • Authorize humanitarian activity
  • Include reporting conditions
  • Address a letter-of-credit transaction

That does not create a new formal category.

Re-export, retransfer and defense-service authorizations are commonly associated with separate export-control systems administered by the Department of Commerce or Department of State rather than being standard OFAC license types.

Bukh Law Firm OFAC License Services

Initial License Analysis

Determining whether the transaction is prohibited and whether a general license or exemption applies.

Specific License Applications

Preparing requests for transactions requiring individual written authorization.

Blocked-Funds Applications

Preparing applications involving frozen bank accounts, restricted payments and blocked property.

Supporting Document Review

Organizing identity, ownership, banking, contractual, financial and transaction documents.

General License Analysis

Determining whether the client satisfies every condition of an existing authorization.

Ownership Review

Analyzing direct and indirect ownership under OFAC’s 50 Percent Rule.

OFAC Follow-Up Responses

Preparing responses to requests for information and supplying additional supporting evidence.

Delayed Application Review

Checking status, updating material facts and identifying issues that may be preventing a determination.

Denied Application Review

Analyzing the stated decision and evaluating whether changed circumstances or new evidence support reconsideration.

License Amendments and Renewals

Requesting changes, extensions and renewal of time-limited authorizations.

License Compliance

Reviewing conditions, transaction documents, reports and recordkeeping requirements after approval.

International License Matters

Advising foreign and Russian clients whose transactions involve U.S. banks, U.S. persons or blocked property.

Coordination With Other Regulatory Requirements

Identifying possible Commerce, State, banking, customs and other authorizations.

What to Do Before Applying for an OFAC License

Before filing:

  • Preserve all transaction and bank records
  • Identify every participant
  • Determine beneficial ownership
  • Obtain the blocking notice if funds are frozen
  • Review applicable sanctions programs
  • Check general licenses and exemptions
  • Define the exact authorization requested
  • Collect supporting documents
  • Translate relevant foreign-language records
  • Identify genuine deadlines
  • Determine whether another agency’s approval is needed
  • Avoid completing the proposed transaction without authorization

Arkady Bukh Law Firm assists individuals and businesses with OFAC specific license applications, supporting documentation, follow-up requests, delayed matters, denied applications and compliance with approved license conditions.

OFAC License Lawyer FAQ

Is Arkady Bukh an OFAC license lawyer?

Yes. Arkady Bukh Law Firm assists individuals and businesses with specific license applications, blocked-funds requests, supporting documents and related sanctions matters.

What are the principal types of OFAC licenses?

OFAC recognizes general licenses and specific licenses. General licenses authorize categories of activity for qualifying persons. Specific licenses are written authorizations issued to particular applicants.

Do I need to apply when a general license covers my transaction?

Generally, an individual application is not required when the transaction is fully authorized by a general license and every condition is satisfied. Reporting and recordkeeping requirements may still apply.

Does submitting an application authorize the transaction?

No. The application does not permit the proposed conduct while review is pending unless another authorization independently applies.

What documents should be submitted?

The documents depend on the transaction but may include identification, ownership records, contracts, invoices, bank statements, payment instructions, source-of-funds evidence and correspondence with financial institutions.

Should foreign-language documents be translated?

OFAC’s published best practices advise against providing foreign-language documents without translation.

How long does an OFAC license application take?

OFAC does not provide one processing period for every case. Timing may depend on complexity, interagency review, application volume and whether additional information is needed.

How can I check the status?

Applicants can use the OFAC Licensing Portal and the Case ID assigned to the application.

What does Pending With Applicant mean?

It generally means that OFAC has requested additional information and is waiting for the applicant’s response.

Should I submit another application if the first application is delayed?

OFAC advises applicants not to submit duplicate requests merely because a decision or update has not yet been issued.

Can I contact the assigned OFAC officer for status updates?

OFAC’s best-practices guidance directs applicants to use the online status system rather than seeking routine updates from the assigned staff member.

What should I do when OFAC requests more information?

Respond to every question promptly, correct any inaccurate information, provide the requested records and explain any material change in the transaction.

Can an application be updated?

Yes. OFAC should be informed when material facts or contact information change. A substantial change may require a supplement, amendment or new application.

Can OFAC deny an application?

Yes. Specific licenses are discretionary and applications are reviewed individually.

Can I formally appeal a denied license application?

OFAC regulations do not provide a formal administrative appeal process. OFAC may reconsider a denial for good cause, including changed circumstances or new relevant information.

Is Returned Without Action the same as denied?

No. A returned application is closed without a licensing decision and is generally accompanied by an explanatory letter. The explanation should be reviewed before deciding whether to correct, restructure or resubmit the request.

Does an approved license authorize every related transaction?

No. It authorizes only the persons, transactions, property and period covered by its terms.

Can an OFAC license expire?

Yes. A license may have an expiration date. OFAC recommends requesting renewal approximately 60 to 90 days before expiration.

Does applying for renewal extend the existing license automatically?

No. Activity outside the current license period remains prohibited unless OFAC grants an extension or another authorization applies.

Does an OFAC license replace an export license?

Not necessarily. Separate authorization may be required from the Department of Commerce, Department of State or another authority.

Can a foreign person apply for a specific license?

Yes. A foreign person may apply when U.S. sanctions affect a transaction, U.S. person, U.S. financial institution or blocked property.