OFAC FAQ (current) # 41 - Questions from Financial Institutions

Date issued: Oct. 26 2026

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TURBOFAC Commentary (93 words)

Notes:

[10-26-26 Update – FAQ amended to specify that U.S. holders of blocked property may “identify [to their customers] the sanctions program or regulations under which the organization blocked the property.”]

To the degree that this guidance includes cases in which the U.S. person bank's actual customer is an SDN or is otherwise blocked, the FAQ impliedly interprets the term "service" to not include this kind of communication with a blocked customer.

See notes to FAQ 68 for discussion on the relationship between this FAQ and the scope of the term "service."