OFAC FAQ (Current) # 33 - Blocking and Rejecting Transactions

Date issued: Oct. 26 2026

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TURBOFAC Commentary (68 words)

Notes:

[10-26-26 Update – FAQ updated to add the word “blocked” to “require that funds earn interest at a commercially reasonable rate”]

See e.g. § 544.203 (Holding of funds in interest-bearing accounts; investment and reinvestment), a generally boilerplate provision setting out expectations for what is and is not to be done with blocked funds. This FAQ provides guidance on the notion of a "commercially reasonable" interest rate.