OFAC Unblocking Application Attorney

Legal Assistance With Frozen Accounts and Blocked Transfers

Arkady Bukh Law Firm assists individuals, business owners, investors and international companies seeking the release of money or other property restricted under regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control.

An OFAC unblocking matter may arise when:

A bank freezes an account
An international wire transfer is blocked
A correspondent bank stops a payment
Funds are placed into a blocked interest-bearing account
A payment is connected with an SDN or blocked entity
A bank identifies a possible sanctions-list match
A client is mistaken for another person with a similar name
A company may be owned by one or more blocked persons
A cryptocurrency exchange restricts digital assets
A person has an ownership interest in property blocked because of another party
A transaction was authorized but remains restricted by a financial institution

Legal representation may include:

Determining why the property was blocked
Reviewing the bank’s blocking notice
Distinguishing an OFAC block from a private compliance hold
Analyzing sanctions-list matches
Addressing mistaken identity and false positives
Reviewing direct and indirect ownership
Applying OFAC’s 50 Percent Rule
Preparing a specific license application
Organizing the supporting evidence package
Responding to OFAC follow-up questions
Communicating with the blocking financial institution
Presenting third-party ownership claims
Reviewing delayed or denied applications
Coordinating an unblocking request with other government proceedings

An application should be based on the actual reason for the restriction. A general statement that the applicant is innocent or that the money is legitimate usually does not answer the legal and factual questions OFAC and the financial institution need to resolve.

Who This Attorney Represents

Arkady Bukh Law Firm assists:

Individuals with frozen personal accounts
Owners of blocked business accounts
Senders and intended recipients of blocked transfers
Foreign nationals
Russian individuals and businesses
S. citizens and permanent residents
International companies
Investors
Beneficiaries of estates and trusts
Non-sanctioned business partners of blocked persons
Third parties with an interest in blocked property
Companies affected by the OFAC 50 Percent Rule
Owners of restricted cryptocurrency
Clients affected by mistaken-identity screening results
Individuals and companies whose previous applications were delayed or denied

Nationality alone does not determine whether property must be blocked.

The analysis depends on the sanctions program, identity of the parties, ownership, transaction route, location of the property and involvement of U.S. persons or financial institutions.

What Is an OFAC Unblocking Application?

An OFAC unblocking application is generally a request for authorization to release or otherwise deal in property that is currently blocked under an OFAC-administered sanctions program.

For blocked funds transfers, OFAC encourages affected parties to submit an electronic application for a specific license authorizing the release of the money.

The application should describe the underlying transaction in detail and include relevant supporting documentation.

The request may concern:

A blocked bank transfer
A frozen deposit account
Securities
Contract payments
Cryptocurrency
Business interests
Estate or trust property
Real estate proceeds
Debt payments
Insurance proceeds
Other tangible or intangible property

The exact procedure depends on why the property was blocked.

An application for a specific license is not the only possible route in every case. A false-positive block, an actual SDN designation, a private bank restriction and a federal seizure order require different analysis.

What Does “Blocked Property” Mean?

Blocking means that assets or other property are frozen.

Property of a blocked person that is within the United States or within the possession or control of a U.S. person generally may not be:

Transferred
Withdrawn
Paid
Exported
Sold
Assigned
Released
Set off against another obligation
Otherwise dealt in without authorization

Blocking does not ordinarily mean that the property has been confiscated or transferred to the United States government.

Title may remain with the owner, but the normal rights to use, transfer or dispose of the property are restricted.

Property can include:

Money
Bank accounts
Checks
Securities
Debt
Contract rights
Goods
Real estate
Business interests
Ships and other vehicles
Digital assets
Present or future interests
Contingent rights

The applicable sanctions regulations should be reviewed to determine how property is defined in the particular program.

Blocked Bank Transfers

A bank transfer may be blocked after a financial institution identifies a blockable interest in the funds.

Possible reasons include:

The sender is an SDN
The beneficiary is an SDN
A participating bank is blocked
A blocked person owns an interest in the funds
A company is blocked under the 50 Percent Rule
The payment concerns blocked property
The payment message contains the name of a sanctioned party
The transfer involves a government or jurisdiction subject to blocking restrictions
The bank believes the customer matches a listed person

Relevant questions include:

Which financial institution imposed the block?
On what date was the payment blocked?
Where are the funds currently held?
What amount and currency are involved?
Who sent the payment?
Who was intended to receive it?
Which intermediary and correspondent banks participated?
Which party allegedly created the blockable interest?
Which sanctions program was cited?
Did the bank provide a blocking reference number?
Was the transaction reported to OFAC?

A detailed transaction chronology is often necessary because an international transfer may pass through several financial institutions before it is stopped.

Frozen Bank Accounts

An entire account may be blocked when the account holder is a blocked person or when the account contains property in which a blocked person has an interest.

The review may involve:

The identity of the account holder
Beneficial ownership
Authorized signatories
Sources of deposits
Other persons with rights in the account
The date the account became restricted
The date of any sanctions designation
Transactions before and after blocking
Whether the account is personal, business, trust or escrow property
Whether non-blocked third parties own part of the balance

Blocked funds held by a financial institution are generally maintained in an interest-bearing blocked account. Only debits authorized by OFAC may ordinarily be made.

An owner should not attempt to transfer or withdraw the funds through another account while the block remains in effect.

Blocked Transactions Compared With Rejected Transfers

A blocked transfer and a rejected transfer are not the same.

Blocked Transfer

A transfer is blocked when the transaction contains property or an interest in property that must be frozen.

The financial institution retains the funds in a blocked account rather than completing or returning the transfer.

Rejected Transfer

A transfer may be rejected when processing it would be prohibited, but no blocked person or other blockable interest is present.

In that situation, the financial institution does not process the payment and ordinarily returns or declines it rather than freezing the property.

A rejected transfer generally does not require an unblocking application because the funds have not been placed into a blocked account.

However, the parties may still need legal advice concerning:

Why the transfer was prohibited
Whether it may be restructured lawfully
Whether a general or specific license is available
Whether the rejection must be reported
Whether the bank has imposed a separate account restriction

Both blocked and rejected transactions may create reporting obligations for the financial institution or other reporting person.

The First Step After a Block

The first step is to identify the legal and operational basis of the restriction.

The client should obtain, when available:

The bank’s blocking notice
The date of the block
The transaction reference number
SWIFT or other payment messages
The name of the blocking institution
The sanctions program cited
The name of the party believed to be blocked
Information about the current location of the funds
Communications with the bank’s sanctions or compliance department
Information concerning any report submitted to OFAC

A customer-service statement that an account was restricted “because of sanctions” may not provide enough information.

The matter may actually involve:

A formal OFAC block
A temporary investigation by the bank
A false-positive name alert
An internal risk decision
A subpoena or law-enforcement hold
A seizure warrant
A civil forfeiture action
A restriction imposed by a foreign regulator

Each situation requires a different response.

False Positives and Mistaken Identity

A false positive occurs when a financial institution identifies a possible match with a sanctioned person, but additional information shows that the customer is not the person on the sanctions list.

This may occur because of:

A common name
Different transliterations of a name
A typographical error
Incomplete customer information
Similar dates of birth
Similar company names
Outdated corporate records
A screening system that gives excessive weight to a partial match

The evidence used to distinguish the customer may include:

Full legal name
Passport
Date and place of birth
Nationality
Addresses
Government identification numbers
Corporate registration records
Business activity
Employment information
Ownership documents
Evidence showing that the listed person is a different individual or entity

A close name match alone should not end the analysis.

Correcting a False-Positive Block

OFAC distinguishes between property that was correctly blocked and property that should never have been blocked because there was no blockable interest.

When a financial institution or other reporting organization determines that it blocked property because of mistaken identity, a typographical mistake or a similar error, that organization may have procedures to release the property and submit an unblocking report.

The organization that blocked the property may also request an OFAC Compliance Release.

The Compliance Release process is available only to the organization that imposed and reported the erroneous block. It is not generally a process that the account owner can independently use in place of the bank.

Therefore, an affected customer may need to:

Contact the financial institution that imposed the block
Provide reliable identity evidence
Ask the institution to reevaluate the match
Request that the institution follow its false-positive unblocking procedure
Apply for a specific license if the institution does not release the property or if the matter is not a qualifying mistaken-identity case

Property must not be released as a false positive if a blocked person actually has an interest in it. Unblocking correctly blocked property without authorization may create sanctions exposure.

When Compliance Release Is Not Appropriate

A Compliance Release is intended for mistaken identity, typographical mistakes and similar errors in which the property never contained a blockable interest.

It is not the correct procedure merely because circumstances changed after a valid block.

For example, Compliance Release generally should not be used when:

A company was correctly blocked under the 50 Percent Rule and later changed ownership
A blocked shareholder later sold an interest
A general license was issued after the property was blocked
The applicant now wishes to complete a transaction with an actual SDN
A blocked person transferred an interest after blocking
The owner argues that the transaction should now be permitted for equitable reasons

Such matters may require a specific license or another applicable authorization.

Ownership Questions and the OFAC 50 Percent Rule

A company may be blocked even though its name does not appear on the SDN List.

Under OFAC’s 50 Percent Rule, an entity is generally considered blocked when one or more blocked persons directly or indirectly own 50 percent or more of it in the aggregate.

Ownership questions may involve:

Direct shareholders
Parent and subsidiary companies
Intermediate holding companies
Beneficial owners
Trusts
Nominees
Aggregation of interests held by several blocked persons
Changes in ownership
Transfers after designation
Disputed or incomplete corporate records

An evidence package may need to show the entire ownership chain rather than only the immediate shareholder.

Relevant documents may include:

Share registers
Certificates of incorporation
Operating agreements
Share-purchase agreements
Trust documents
Organizational charts
Beneficial-ownership declarations
Audited financial reports
Records showing the date of a transfer
Evidence of payment for a genuine divestment

Control Is Not Always Ownership

OFAC’s 50 Percent Rule is based on ownership.

Control by a blocked person, without aggregate blocked ownership of at least 50 percent, does not by itself automatically block an entity under that rule.

However, the direct participation of an SDN may still make a particular transaction prohibited. OFAC can also separately designate an entity controlled by a blocked person.

The ownership and transaction analyses should therefore be conducted separately.

Changes in Ownership After Blocking

A later change in ownership does not automatically release property that was correctly blocked.

The review may need to determine:

Whether the entity was blocked at the time of the transaction
Whether the property was properly frozen
When the ownership change occurred
Whether the transfer happened outside U.S. jurisdiction
Whether a U.S. person participated
Whether the transfer was genuine
Whether economic benefit and control actually changed
Whether other blocked owners remain
Whether OFAC authorization is required to release previously blocked assets

A current ownership chart alone may not resolve why the property was blocked at an earlier date.

Third-Party Ownership Claims

A non-sanctioned person may claim ownership of all or part of blocked property.

Examples may involve:

Joint accounts
Escrow funds
Client money
Trust property
Estate assets
Funds held by an agent
Payments collected for another company
Investor property
Customer assets held by an exchange
Property transferred before a designation

The application should explain:

Who legally owns the property
Who supplied the funds
Who controls the account
Whether the blocked person has any legal or beneficial interest
When the ownership interest arose
What contracts or records support the claim
Whether the claimant received value in exchange
Whether the arrangement is genuine and documented

OFAC may examine substance rather than relying solely on the name placed on an account or contract.

Building the Evidence Package

An unblocking application should include evidence tailored to the reason for the block.

The package may include:

Identity Documents

Passport
National identity card
Date and place of birth
Address records
Immigration documents
Corporate identification numbers

Ownership Documents

Shareholder registers
Corporate formation records
Organizational charts
Beneficial-ownership information
Trust or estate documents
Contracts establishing ownership
Evidence of transfers or divestments

Transaction Records

SWIFT messages
Bank statements
Payment instructions
Invoices
Purchase orders
Contracts
Correspondent-bank information
Transfer confirmations
Blockchain transaction records

Source-of-Funds Evidence

Sale agreements
Payroll or income records
Tax documents
Loan agreements
Investment statements
Business revenue records
Inheritance documents
Accounting records

Purpose-of-Payment Evidence

Commercial contracts
Legal invoices
Medical bills
Real estate documents
Settlement agreements
Insurance documents
Estate-distribution instructions
Records of goods or services provided

Evidence Concerning the Block

Blocking notice
Reference number
Bank correspondence
Compliance questionnaires
Information identifying the suspected sanctions match
Reports or notices from an exchange
Earlier OFAC applications or licenses

Foreign-language documents should be accompanied by accurate English translations.

Documents should be organized and explained. A large unsorted collection of bank statements or corporate files may not show how each exhibit supports the request.

Preparing the Transaction Narrative

The application should provide a clear chronology.

The narrative may explain:

Who the applicant is
What property is blocked
Where it is held
When and how it was blocked
Who sent and was intended to receive the property
The purpose of the transaction
The source of the money
Every bank or intermediary involved
The suspected blocked party or interest
Why the applicant believes release is legally appropriate
Whether a false-positive match occurred
Whether the 50 Percent Rule applies
Whether a general license is relevant
Whether the applicant seeks a specific license
Whether any third party owns an interest
Whether another government proceeding is pending

The requested authorization should be precise.

For example, the application may request authority for a named bank to release a specified amount to an identified beneficiary through a proposed payment route.

Applying for a Specific License to Release Funds

OFAC encourages electronic applications for the release of blocked funds.

A specific license request may be appropriate when:

The property was correctly blocked but release is now requested
A blocked person has an actual interest
The transaction requires discretionary authorization
A general license does not cover release
Ownership changed after a valid block
A third-party claim cannot be resolved by the bank
The blocking institution will not release property as a false positive
The property owner cannot use the Compliance Release procedure
The sanctions program provides a licensing policy relevant to the request

The application does not authorize the bank to release the property while it is pending.

The property must ordinarily remain blocked unless:

A general license authorizes release
OFAC issues a specific license
The institution properly corrects an erroneous block
The relevant person is delisted
Another applicable authorization permits release

For a broader discussion of specific licenses, visit the OFAC License Lawyer page.

OFAC Follow-Up Requests

OFAC may ask for additional information after reviewing the application.

Questions may concern:

Identity
Ownership
The role of an SDN
The source of funds
The payment purpose
The bank that imposed the block
The current location of the property
The proposed release instructions
A potentially applicable general license
Conflicting dates or amounts
Missing contracts
Another person with an interest in the property
Changes after the original application
Related litigation or investigations

A response should:

Address every question
Correct prior inaccuracies
Explain unavailable documents
Include translations
Identify changes since filing
Provide updated payment instructions
Remain consistent with the transaction history
Be submitted within the stated deadline

An incomplete or inconsistent response can delay the application and raise further questions.

Delayed Unblocking Applications

OFAC does not provide one fixed processing period for every application.

Review may take longer when the matter involves:

Several countries or banks
Complex ownership
Multiple blocked persons
A disputed sanctions-list match
Interagency consultation
Incomplete documents
Repeated requests for information
An ongoing criminal or regulatory investigation
Changes in the proposed transaction
National-security or foreign-policy considerations

During the review, the applicant should:

Use the official Licensing Portal to check status
Preserve the Case ID
Respond promptly to OFAC questions
Update material facts
Confirm that contact details remain current
Review new sanctions actions and general licenses
Avoid filing duplicate applications merely because review is taking time
Avoid attempting to move the blocked property without authorization

A delayed application does not give the applicant permission to proceed.

Denied or Returned Applications

An unblocking request may be:

Approved
Denied
Returned without action
Closed
Left pending while OFAC requests more information

A denial and a return without action are not identical.

A returned application may indicate that:

The request is incomplete
A license is not required
Another procedure is more appropriate
The requested activity is already authorized
OFAC cannot act on the request in its current form

OFAC regulations do not provide a routine formal administrative appeal from the denial of a specific license application. OFAC may reconsider a determination for good cause, such as material changed circumstances or new relevant information.

A renewed request should explain:

The earlier Case ID
What decision was issued
What material information is new
What circumstances changed
Whether ownership changed
Whether the proposed payment route changed
Whether a new general license was issued
Whether a problematic party was removed
Why the new evidence affects the licensing analysis

Simply resubmitting the same application without addressing the earlier decision is unlikely to improve the record.

Unblocking Compared With SDN Delisting

An OFAC unblocking application and an SDN delisting petition address different problems.

Unblocking Application

An unblocking application concerns particular property or a particular transaction.

It may seek authorization to release:

A bank transfer
A frozen account
Securities
Cryptocurrency
Contract payments
Other blocked assets

The applicant may or may not be personally designated on an OFAC list.

SDN Delisting Petition

A delisting petition seeks removal of a person, entity or property from an OFAC sanctions list.

It is appropriate when the petitioner is actually listed or otherwise formally sanctioned.

A delisting petition generally addresses:

The legal basis of designation
The designation criteria
Mistaken identity in the designation itself
Insufficient basis for designation
Material changed circumstances
Changes in conduct, ownership or relationships
Every authority under which the person is listed

A person who is not listed but was mistaken by a bank for someone with a similar name generally does not need to seek removal from the SDN List because there is no listing to remove.

Instead, the matter should be addressed with the blocking institution, through the false-positive procedures or, when appropriate, through a specific license request.

For SDN designations and delisting, visit the OFAC Sanctions Attorney page.

What Happens When a Person Is Delisted?

When OFAC removes a person from the SDN List, neither a specific license nor a Compliance Release is generally required solely to unblock property based on that former designation.

However, the financial institution may still need to:

Verify the delisting
Confirm that no other sanctions authority applies
Review ownership by other blocked persons
Complete required unblocking reports
Confirm the identity of the account holder
Address another independent legal restriction

Delisting one person may not release property if another blocked person continues to have an interest.

Unblocking Compared With Federal Seizure or Forfeiture

An OFAC block differs from a federal seizure.

OFAC Block

Property is frozen under sanctions regulations. Ownership ordinarily remains with the owner, but dealing in the property is restricted.

Federal Seizure

Government agents may take control of property under a warrant or another judicial process because they allege that the property is evidence, criminal proceeds or subject to forfeiture.

A specific OFAC license may not be sufficient to release property restrained under a seizure warrant, criminal forfeiture allegation or civil forfeiture complaint.

The client may need to respond in federal court or through a separate administrative forfeiture process.

The blocking notice, court records and communications from the government should be reviewed before deciding which procedure applies.

Cryptocurrency and Digital Assets

OFAC blocking rules apply to cryptocurrency and other digital assets.

A crypto unblocking matter may involve:

A frozen exchange account
Cryptocurrency associated with an SDN wallet
Indirect blockchain exposure
A restricted stablecoin address
Digital assets held for customers
A multisignature wallet
An exchange deposit address
A mistaken wallet attribution
Assets restricted because of a sanctions investigation

The evidence package may include:

Exchange statements
KYC records
Wallet addresses
Blockchain transaction history
Proof of private-key control
Bank transfers used to purchase the assets
Communications concerning the transaction
Source-of-funds records
Evidence distinguishing custodial and personal assets
Information about other users of the wallet

A blockchain analytics label does not by itself establish who owns a wallet, who authorized a transfer or what the client knew about earlier transactions.

For broader cryptocurrency matters, visit the Cryptocurrency and Crypto Law Attorney page.

Bukh Law Firm OFAC Unblocking Services

Initial Blocking Analysis

Determining whether the restriction is an OFAC block, a private compliance hold, a false-positive alert or another government action.

Blocked Transfer Applications

Preparing specific license requests involving international wires and correspondent-bank payments.

Frozen Account Representation

Assisting owners of restricted personal, corporate, estate and trust accounts.

False-Positive Resolution

Preparing identity evidence and communicating with institutions that may have mistaken the client for a sanctioned person.

Ownership and 50 Percent Rule Analysis

Reviewing direct, indirect and aggregate ownership by blocked persons.

Evidence Package Preparation

Organizing identity, ownership, transaction, source-of-funds and payment-purpose documents.

OFAC Specific License Applications

Requesting authority to release property that cannot be unblocked through a general license or false-positive procedure.

Follow-Up Responses

Answering OFAC questions and supplying additional supporting evidence.

Delayed Application Review

Checking official status, updating material facts and addressing outstanding information requests.

Denied Application Review

Evaluating whether new evidence or changed circumstances support reconsideration.

Third-Party Ownership Claims

Presenting the rights of non-sanctioned persons with an interest in blocked property.

Bank and Exchange Communication

Addressing compliance questions from banks, payment providers and cryptocurrency exchanges.

International and Russian Sanctions Matters

Representing foreign clients whose assets are restricted through U.S. banks, U.S. persons or OFAC sanctions programs.

Related Federal Proceedings

Coordinating OFAC licensing with seizures, forfeiture proceedings and federal investigations.

What to Do After Property Is Blocked

Do not attempt to move, conceal or withdraw the property.

Preserve:

The blocking notice
Bank and exchange statements
Payment instructions
SWIFT messages
Contracts and invoices
Identity documents
Corporate ownership records
Source-of-funds evidence
Communications with financial institutions
General and specific licenses
Blockchain records
Documents showing third-party ownership
Earlier OFAC submissions

Determine:

Who imposed the restriction
Whether the property was blocked or the transaction merely rejected
Which sanctions program applies
Which person or entity allegedly had an interest
Whether the match may be false
Whether the 50 Percent Rule applies
Whether a general license authorizes release
Whether a specific license is required
Whether the property is also subject to seizure or forfeiture
Whether the applicant or another party is actually listed on the SDN List

Arkady Bukh Law Firm assists individuals and businesses with blocked transfers, frozen accounts, mistaken identity, ownership disputes and applications to release property restricted under OFAC sanctions.

OFAC Unblocking Application FAQ

Is Arkady Bukh an OFAC unblocking application attorney?

Yes. Arkady Bukh Law Firm assists clients with frozen accounts, blocked transfers, false-positive sanctions matches, specific license applications and supporting evidence.

Does blocking mean the government owns my money?

Not ordinarily. Blocking freezes the property and prevents transfers or dealings. Ownership generally remains with the owner unless the property is separately forfeited or transferred through another legal process.

What is the difference between a blocked and rejected transfer?

A blocked transfer is frozen because it includes a blockable interest. A rejected transfer is not processed because the transaction is prohibited, but the property itself is not required to be frozen.

How do I apply to release a blocked transfer?

OFAC encourages applicants to submit an electronic specific license application and include a detailed explanation of the underlying transaction and supporting documents.

Can the bank release funds blocked because of mistaken identity?

The institution that blocked the property may reevaluate the match. If it determines that the block resulted from mistaken identity, a typographical error or a similar mistake, it may follow the applicable unblocking and reporting procedures.

Can I request a Compliance Release directly?

The Compliance Release procedure is available to the organization that mistakenly blocked and reported the property. A customer should generally work with that institution or apply for a specific license when appropriate.

What documents are needed for a false-positive case?

Relevant documents may include a passport, date and place of birth, address, nationality, corporate records and other information distinguishing the client from the listed person.

Is a false positive the same as SDN delisting?

No. A false positive means the customer is not the person listed. Delisting is the process used by a person, entity or property that is actually included on an OFAC sanctions list.

Does a company have to be named on the SDN List to be blocked?

No. A company may be treated as blocked if one or more blocked persons directly or indirectly own at least 50 percent of it in the aggregate.

Does control by an SDN always block a company?

Not automatically under the 50 Percent Rule if blocked ownership is below 50 percent. However, transactions involving the SDN may remain prohibited, and OFAC may separately designate the company.

Does a later ownership change automatically release blocked funds?

No. Property that was correctly blocked may remain restricted after ownership changes. A specific license or another OFAC authorization may be required.

What should be included in an evidence package?

The package may include identity records, ownership documents, transaction records, source-of-funds evidence, payment-purpose documents and communications concerning the block.

Should foreign-language documents be translated?

Yes. Relevant documents should generally be accompanied by accurate English translations.

Does submitting an application release the funds?

No. Submission alone does not authorize the financial institution to release blocked property.

How long does an unblocking application take?

OFAC does not provide one universal processing period. Timing depends on the sanctions program, complexity, ownership, supporting evidence and whether additional review is required.

Can OFAC request additional documents?

Yes. OFAC may request information about identity, ownership, transaction purpose, payment routing, source of funds and other persons with an interest in the property.

Can a denied application be appealed?

OFAC regulations do not provide a routine formal administrative appeal from a specific license denial. OFAC may reconsider a decision for good cause based on changed circumstances or new relevant information.

Does delisting automatically authorize unblocking?

When a person is removed from the SDN List, neither a specific license nor a Compliance Release is generally required solely because of the former designation. The institution must still confirm that no other blocking basis applies and complete applicable reporting.

Can an OFAC application release property seized in a criminal case?

Not necessarily. Property held under a seizure warrant or forfeiture proceeding may require a separate response in federal court or through another legal process.

Can cryptocurrency be blocked by OFAC?

Yes. Digital assets are treated as property for sanctions purposes and may be restricted by exchanges or other persons subject to U.S. jurisdiction.