OFAC FAQ (Current) # 39 - Blocking and Rejecting Transactions

Date issued: Sep. 10 2002

TURBOFAC Commentary (153 words)

Notes:

1) From 2016-2020, NY State had a specific license to escheat funds in accordance with its abandoned property laws that did not require case-by-case authorizations from OFAC. See LICENSE No. MUL-2013-305239-3, but that license has expired and OFAC has said that, as of 1/15/2021, NY State does not have authorization to escheat funds without OFAC needing to authorize each transfer. It is unclear what if any other states have licenses similar to LICENSE No. MUL-2013-305239-3. That license was issued without there having been any notification to the public (and while this FAQ was still active and suggested that NY State would need specific authorization for each escheatment). See comments to Case No. SDGT-2019-363638-1 [Documents related to related legal challenge in original PDF]. The existence of non-public escheatment licenses can complicate efforts to recover funds blocked by OFAC.