General Note on Short Licenses for the Unblocking of Funds Transfers / Accounts Blocked Erroneously or Otherwise (System Ed. Note)

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TURBOFAC Commentary (645 words)

General Note on Short Licenses for the Unblocking of Funds Transfers / Accounts Blocked Erroneously or Otherwise

(i) Form of License/Authorization

OFAC licenses for the unblocking of stopped electronic funds transfers can take various forms. Sometimes OFAC authorizes the straight-through processing of the stopped wire. This can occur when the payment was initially duly blocked (License No. SY-2014-307676-1) or when the bank stopping the payment mistakenly believed that a blocked person had an interest therein (License No. FNK-2015-316677-1). In those case, OFAC says “[OFAC] has determined that [blocking bank] authorized to process the transfer in accordance with the original payment instructions.”

Sometimes, OFAC will only authorize the rejection of a duly blocked transfer (License No. lA-2021-376547-1; License No. IA-2021-376893-1) (OFAC has carefully reviewed the information presented and otherwise available to it in connection with this...