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OFAC Licensing and Litigation

June 30, 2020

OFAC Compliance for Financial Institutions: What Do Banks, Creditors, and SDNs Need to Know?

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All U.S. entities that do business with specially designated nationals (SDNs) have compliance obligations that are enforced by the Office of Foreign Assets Control (OFAC). However, financial institutions are in a unique position that mandates extensive OFAC compliance policies and procedures. While it is crucially important for banks to be aware of what is required, creditors and SDNs seeking access to blocked assets held by U.S. financial institutions will be well-served to familiarize themselves with financial institutions’ compliance obligations as well. Read More

Categories: OFAC Licensing and Litigation

November 29, 2019

OFAC Licenses: Do You Need a General License or a Specific License?

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In order to transfer assets as a specially designated national (SDN) or to engage in transactions involving an SDN’s blocked assets, it is necessary to obtain a license from the Office of Foreign Asset Control (OFAC). OFAC issues two types of licenses – general and specific – and all license applications must contain information that is specific type of license being sought. Due to the complexities involved in the application process, it is advisable for all SDNs, creditors and other license applicants to seek guidance from an OFAC attorney.   Read More

Categories: OFAC Licensing and Litigation