THE CHALLENGE
A specific license application must clearly identify the sanctions program, parties, transaction, legal basis, and facts supporting authorization. Incomplete records, unclear ownership, or a weak rationale can lead to questions, delays, or denial. A denial is final agency action with no formal appeal, although OFAC may reconsider for good cause based on changed circumstances or new information.
How does this get solved?
We first determine whether a general license already authorizes the transaction, a specific license is required, or no OFAC authorization is needed. We then map the parties, ownership, transaction structure, regulatory criteria, and supporting evidence. The application explains what authorization is requested and why, while contingency planning protects the business timeline during review.
Rapid intake of listing matters
When authorization may be required, we assess the legal path, feasibility, required information, and realistic timeline.
Initial intake typically includes: the transaction and parties, ownership and control, applicable sanctions program, legal basis, business purpose, counterparties and intermediaries, payment structure, prior OFAC submissions, bank requirements, timing, and supporting agreements.
OUR APPROACH
How we build licensing requests
Assess licensing path
Confirm whether authorization is required and identify any applicable general license, exemption, exception, or licensing policy. Evaluate the parties, ownership, activity, transaction route, and intermediaries to determine the appropriate path and resolve issues before filing.
Build the application
Develop a clear explanation of the transaction, legal basis, commercial context, and justification for authorization. Address ownership, payment routing, end use, timing, compliance controls, and prohibited interests. Organize the supporting documents and anticipate OFAC’s likely questions.
Manage the review
Submit through the appropriate channel and manage information requests and supplemental filings. Keep the record consistent, monitor the application, and coordinate banks, counterparties, contingencies, and timelines. If authorization is granted, advise on license conditions, reporting, recordkeeping, and implementation.
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 DETAILSNeed authorization for a sanctions-related transaction or activity?
We advise clients on OFAC licenses, authorizations, blocked transactions, and cross-border activities involving sanctions considerations.