42. What should I do if a blocked person, such as a person listed on OFAC's SDN List, tries to open an account? What if a non-blocked person wants to transact with a blocked person?
Generally, U.S. persons should neither open an account for a blocked person nor permit transactions with blocked persons.
U.S. persons, including foreign branches of U.S. financial institutions and others subject to U.S. jurisdiction, are generally prohibited from opening an account for any individual or entity named on OFAC's Specially Designated Nationals and Blocked Persons List (SDN List) or for any individual or entity that is otherwise blocked (such as a blocked government entity or an entity blocked pursuant to OFAC’s "50 Percent Rule"). For more information, see the Basic Information on OFAC and Sanctions FAQ topic page on OFAC's website.
If a U.S. person gains control or possession of any...
[10-26-26 Update – FAQ amended to add the last paragraph, which specifies that “Before taking action” to block funds, “it is important to verify that the individual or entity attempting to open the account or involved in the customer's transaction is the same as the person listed on OFAC's SDN List or that the person is otherwise subject to blocking,” and that “[a]n institution may need to conduct further due diligence, such as requesting additional identifying information from the individual or entity, to determine whether the match is a ‘false positive’”. This further makes clear that, even where there may be a good chance that there is a blockable interest in funds, action to block (and report) the funds should not be taken until an investigation is done to confirm that the property at issue is blockable]
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