Blocked vs Frozen vs Seized Assets: The Legal Difference Under OFAC
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What’s the difference between “blocked,” “frozen,” and “seized” (confiscated) property?

“Blocked” and “frozen” mean the same thing under OFAC— legal title stays with the owner, but the owner cannot transfer, withdraw, or deal in the property without OFAC authorization. “Seized” or “confiscated” is different: it is a permanent transfer of ownership, typically ordered by a court, that ends the original owner’s legal interest entirely. This only happens through a separate judicial or administrative forfeiture proceeding — blocking under the International Emergency Economic Powers Act (50 U.S.C. §§ 1701–1706) does not by itself confiscate anything. The distinction is central to the current debate over Russian Central Bank reserves: roughly $300 billion remains blocked, not confiscated, because permanently transferring sovereign assets raises separate sovereign-immunity questions a blocking order alone cannot resolve.

Marcin Ajs
Associate Partner
An Associated Partner at the firm Dziekański Chowaniec Ajs and a member of the European Criminal Bar Association, Marcin Ajs is an expert in white-collar crime, fiscal criminal statutes, compliance policies, and cross-border criminal law. Since 2014, he has managed complex cases under the European Arrest Warrant regime, extradition protocols, and INTERPOL inquiries, focusing on corruption, laundering of illicit funds, fraudulent schemes, and theft of proprietary business information.

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