Can you use a frozen account to pay a lawyer or cover living expenses?

Not automatically — but a defined path exists. General blocking rules prohibit any debit from a frozen account without OFAC authorization, so covering attorney’s fees or personal living expenses requires a Specific License, the same category used for winding down a blocked business. For legal fees specifically, OFAC maintains a standing published policy — Guidance on the Release of Limited Amounts of Blocked Funds for Payment of Legal Fees and Costs — under which a blocked U.S. person may apply to release a limited amount of blocked funds to pay for administrative reconsideration or judicial review of their own designation, provided no alternative funding source is available. Living-expense releases are handled case by case and are far less standardized; applicants must show the funds are strictly for their own necessities, not commercial use, and review can take months.