What happens to frozen assets if the owner dies?
Death does not unfreeze the property. Blocked assets pass into the decedent’s estate still blocked, and heirs or an executor cannot distribute, sell, or transfer them without OFAC authorization — the block follows the property, not the person. Some programs address this directly: under the Cuban Assets Control Regulations, 31 CFR § 515.523 authorizes transactions incident to administering and distributing a blocked Cuban decedent’s estate, and property distributed under that license becomes unblocked provided no remaining Cuban national retains an interest in it. Where no comparable general license exists — as under the Iranian Transactions and Sanctions Regulations (31 CFR Part 560) — the executor must apply for a Specific License before probate can proceed, documenting the estate’s assets and beneficiaries and confirming none are themselves blocked persons.
