OFAC FAQ (Current) # 32 - Blocking and Rejecting Transactions

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (303 words)

Notes:

[10-26-26 Update – FAQ updated to specify that FI’s can use the omnibus account methodology for blocking funds in a way that is consistent with “regulatory requirements, provided there is a clear audit trail, including so the institution can later unblock specific funds with the appropriate interest, if authorized to do so” The FAQ also clarifies that “institutions maintaining blocked funds in omnibus accounts must include in their Annual Report of Blocked Property a disaggregated list showing each blocked asset contained within the omnibus account.” The FAQ also makes clear that the 10-day clock on blocked report filing obligations begins running once the funds have been assessed as containing a blockable interest. OFAC says that “Once it is determined that funds need to be blocked,” the funds must be placed into a segregated account, and “holder of the blocked funds must then” (i.e. after the blocking determination) report...

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OFAC FAQ (Current) # 32 - Blocking and Rejecting Transactions

TURBOFAC Commentary (303 words)