THE CHALLENGE
Assets may be restricted because of a designated party’s interest, OFAC’s 50 Percent Rule, the transaction path, incomplete information, or a financial institution’s sanctions controls. The explanation initially provided by a bank may not tell the whole story. Once property has been reported as blocked, release may require additional evidence, OFAC authorization, or both. Incomplete submissions and inconsistent explanations can prolong the restriction and make recovery more difficult.
How does this get solved?
The first step is determining what actually happened: an OFAC block, a rejected transaction, an internal compliance hold, or another restriction. We trace the parties, ownership, payment chain, applicable sanctions program, and asserted legal basis. The strategy may involve resolving the issue with the financial institution, demonstrating that no prohibited interest exists, relying on an applicable authorization, submitting an unblocking request, applying for a specific license, or pursuing further administrative or judicial relief. Parallel planning protects business continuity while the recovery process moves forward.
Rapid intake of listing matters
When funds or property are restricted, the priority is preserving the transaction record and preventing inconsistent communications. We move quickly to determine who imposed the restriction, why it occurred, what was reported to OFAC, and what information is needed to challenge or resolve it.
Initial intake typically includes: blocking or rejection notices, bank communications, account and payment records, SWIFT or wire information, contracts and invoices, the source and intended use of funds, ownership and control information, sanctions-screening results, relevant counterparties, and any prior OFAC submissions or licenses.
our approach
How we move blocked assets toward release
Clarify the restriction
Determine whether the restriction is a legal block, a rejected transaction, or an internal financial-institution hold. Identify the applicable sanctions program, listed parties, ownership interests, intermediaries, and transaction path. Test the stated basis against the governing regulations and OFAC guidance rather than assuming the initial characterization is correct. A clear diagnosis determines whether the matter should be addressed with the institution, OFAC, or both.
Build the recovery record
Develop a coherent and verifiable record explaining the parties, ownership, transaction purpose, source and intended use of funds, and absence of any prohibited interest when applicable. Address name matches, ownership questions, payment-routing issues, and inconsistencies directly. Organize declarations, agreements, payment records, compliance materials, and other supporting documents around the legal standard governing release or authorization.
Drive the release
Present the request through the appropriate channel and manage follow-up communications with the financial institution and OFAC. Respond to requests for additional information, keep the record consistent, and address new questions before they cause further delay. Coordinate licensing, revised transaction structures, counterparty communications, and other continuity measures while the request is pending. If the process stalls, evaluate escalation options based on the facts, governing authority, and procedural posture.
Latest outcomes
Outcomes that keep you operational
Humanitarian operations preserved amid terror-financing designation threat
A large international humanitarian relief charity facing threatened OFAC designation on terror-financing allegations prevented listing through pre-designation advocacy, credible counter-terrorist-financing procedures, and resolution of frozen charitable transfers.
SEE THE DETAILS
Platform operations secured amid sanctioned-party access allegations
A global cryptocurrency exchange facing threatened OFAC designation for sanctioned-party access prevented listing through coordinated pre-designation defense, independent investigation, and transparent agency engagement.
SEE THE DETAILSAssets blocked or funds frozen?
We advise clients on OFAC licensing, blocked funds, recovery strategies, and continuity issues arising under U.S. sanctions regulations.