OFAC Blocking vs. Rejection: Understanding Transaction Sanctions
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Do all OFAC programs automatically block transactions?

No, not all OFAC programs automatically require the blocking of transactions. OFAC regulations are tailored to the objectives of each sanctions program. In some cases, the president determines the need for comprehensive asset freezes, while in others, more limited measures are applied, such as import or export bans. Some OFAC programs only require the rejection of transactions without asset blocking. For example, a payment between two foreign companies involving Iran would be rejected by a U.S. bank but not blocked. It is important to study the specific requirements of each sanctions program on the OFAC website.

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