How to Legally Release Funds Frozen Under U.S. Sanctions
The client faced a blockage of an international bank transfer due to U.S. sanctions restrictions. We conducted a legal analysis, prepared a package of documents, and facilitated interaction with the regulator, as a result of which an official OFAC license was obtained, and the transfer was allowed to proceed.
Problem
The client’s international payment was blocked by the bank under U.S. sanctions compliance (OFAC).
Such blockages create serious risks:
- freezing of funds for an indefinite period
- risk of final cancellation of the transaction
- reputational and commercial losses
- complex interaction with banks and regulators
The client required official permission from the US regulator to execute the payment.
How the situation was resolved step by step
- Conducted a legal analysis of the situation
We studied the grounds for blocking, the participants of the transaction, and the applicable sanctions regulation. - Developed a legal strategy
Determined the optimal path — obtaining an individual OFAC license. - Prepared a package of documents
Collected evidence of the legality of the operation, the economic rationale of the payment, and the absence of sanction risks. - Accompanied communication with the regulator
Corresponded and responded to regulator requests, monitored the review process. - Coordinated interaction with the bank
Ensured the correct provision of information to the bank and compliance with compliance procedures.
What result
– An official OFAC license has been obtained.
– Permission for translation processing confirmed.
– The bank received the right to execute the transaction according to the initial instructions.
– The client saved funds and avoided financial losses.
– The regulator explicitly stated in the document that Citibank is authorized to process the transfer in accordance with the payment instructions after verifying the information.
– Faced with a payment blockage due to sanctions or bank compliance?
We will help:
- conduct a legal analysis
- build a strategy for unlocking
- prepare documents for OFAC
- accompany the case to the result
