OFAC license, blocked payments and delisting

• The bank's letter or message saying the funds are blocked, rejected or held, with the dates.
• The payment instructions (for example the SWIFT message), reference numbers, amount and value date.
• The name of the bank that filed the blocking report with OFAC (OFAC FAQ 51).
• Invoices, contracts, bills of lading and other documents behind the payment.
• Names and addresses of everyone involved in the transaction, including the banks.
• For a name match: passport, Turkish ID card, date and place of birth; for a company, the Trade Registry Gazette (Ticaret Sicil Gazetesi) and signature circular.
• English translations of Turkish documents: OFAC asks applicants not to send untranslated documents.
• For a delisting petition: the listed name and its UID from OFAC's Sanctions List Search, the listing date, ID or registration documents and, for a representative, a power of attorney.

• Filing a delisting petition when you were only mistaken for a listed person: that process is for listed persons (OFAC FAQ 897).
• Applying for a specific license when a general license already covers the payment (31 CFR 501.801(a)).
• Missing information: OFAC generally does not process a release request without a matching blocking report (OFAC FAQ 51).
• Untranslated documents, duplicate applications, or applications sent by email instead of the Licensing Portal (OFAC's quick-reference guide for applicants).
• Inconsistent or false statements: OFAC may deny the petition, and knowingly false statements can bring criminal penalties (OFAC FAQ 897).
• Missing a questionnaire deadline without asking for more time: OFAC may deny the petition.
• Iran-related requests: since 10 September 2026 OFAC presumes denial, except as required by law or in exceptional and urgent circumstances.
• Moving assets to other parties to show “changed circumstances”: OFAC may treat such transfers as sanctionable conduct.

• Your bank in Turkey closed or froze your account under Turkish law: that is a Turkish-law matter. See AML records and bank closures and Turkish-law matters.
• The bank names no sanctions program and speaks only of its own review: start with AML records and bank closures.
• You were listed by the State Department rather than OFAC: the State Department runs its own removal review (OFAC FAQ 897).
• An arrest, a criminal charge or an extradition request: see extradition.
• U.S. export controls, such as the Commerce Department's Entity List: another agency's list, on which OFAC does not advise (OFAC FAQ 5).

Who this is for

• Turkish exporters and importers whose U.S.-dollar wire was stopped by a U.S. bank, including an intermediary bank.
• People and companies whose bank says their funds are “blocked” or “frozen” because of sanctions.
• Companies and individuals on the SDN List or another OFAC list who want to ask for removal.
• Businesses whose payment is on hold while the bank has not said whether OFAC is involved.

Key requirements

• Blocking or rejecting: if a blocked person, such as someone on the SDN List, has an interest in the payment, the bank must freeze it in a blocked, interest-bearing account. If the payment is prohibited but no blocked person is involved, the bank rejects it and it is returned to the sender (OFAC FAQs 5 and 36).
• Reporting: the bank must report a block within 10 business days of the date the property became blocked (31 CFR 501.603(b)(1)), a rejected payment within 10 business days (31 CFR 501.604(c)), and a later release within 10 business days (31 CFR 501.603(b)(3)).
• Release: OFAC does not seize or hold blocked funds, but the bank needs OFAC's authorization to release them. The usual route is a specific license application filed through OFAC's online Licensing Portal (OFAC FAQ 51; 31 CFR 501.801). Any person with an interest in the transaction may apply.
• General licenses first: if a general license already covers the payment, OFAC does not grant a specific license for it (31 CFR 501.801(a)).
• Delisting: a listed person may petition OFAC for administrative reconsideration, arguing that there was an insufficient basis for the listing or that the circumstances have changed (31 CFR 501.807).
• Name matches: delisting is only for people who are actually listed. OFAC sends people mistaken for a listed person to its Compliance Hotline, but it does not confirm matches or false positives; the bank makes that call (OFAC FAQs 5 and 897).
• Blocked by mistake: the bank that blocked the funds can unblock them and file an unblocking report, or ask OFAC for a “Compliance Release” under 31 CFR 501.806. Only that bank can use the Compliance Release; you work through the bank or apply for a license (OFAC FAQ 1196).

What to check with an attorney

• Whether the bank is citing OFAC at all, and which sanctions program and legal authority it names.
• Whether a general license or an exemption already covers the payment.
• Which bank filed the blocking report and on what date, so the license application can refer to it.
• Whether your documents clearly separate you from the listed person.
• For a listed person: every authority you were listed under, and whether “insufficient basis” or “change in circumstances” fits the facts.

Fees and rules reviewed 16 Oct 2026. Sources below.

Official sources:

1. OFAC FAQ 51: How can I get my blocked funds released?
2. OFAC FAQ 58: How long will a license application take?
3. OFAC FAQ 5: Assessing potential name matches
4. OFAC FAQ 36: Blocking versus rejecting a transaction
5. 31 CFR 501.603: Reports of blocked and unblocked property
6. 31 CFR 501.604: Reports of rejected transactions
7. 31 CFR 501.801: Licensing
8. 31 CFR 501.807: Delisting procedures
9. OFAC FAQ 897: How to ask for removal from an OFAC list
10. OFAC: How to Request Removal from an OFAC Sanctions List
11. OFAC FAQ 1196 and 31 CFR 501.806: Property blocked in error
12. OFAC Specific Licenses and Licensing Portal
13. OFAC guidance on legal fees from blocked funds (23 July 2010)
14. 31 CFR 594.315: Definition of U.S. person
15. 31 CFR 587.507: Legal fees from funds outside the U.S. (Russia program)
16. 31 CFR 594.506: Legal services (Global Terrorism program)
17. OFAC Quick-Reference Guide: best practices for license applicants
18. OFAC Statement of Licensing Policy on Iran-related requests (10 September 2026)
19. OFAC Compliance Hotline
20. 31 CFR 501.601: Recordkeeping

What changed: rewritten around the first question (OFAC block, rejection or bank hold), with OFAC's 10-business-day reporting rules, the license and delisting steps and OFAC's legal-fee policy.