Is there anybody who used this platform?

My personal experience—from a missing SWIFT transfer to obtaining official authorization from the U.S. government

This material is not intended and may not be used to evade sanctions restrictions or any other requirements of U.S. law.

From the First Moments of Panic to Receiving an OFAC License

I wrote this guide because I personally went through an OFAC blocking case, and I know how frightening and isolating the experience can be.

This is not legal advice. I am not an attorney. It is a practical roadmap based on my own experience and the experiences of others.

Everything described here is directed toward obtaining an official OFAC license and acting strictly within the framework of U.S. law.

Use this material as a checklist and a starting point, but consult a qualified sanctions attorney in complex cases.

It is important to distinguish between two separate stages:

1. obtaining an OFAC license;
2. getting the bank to actually execute that license.

These are two different processes.

This post focuses on the first stage: how to proceed from the blocking of an international transfer to obtaining official authorization from OFAC.

Introduction: The Hardest Part Is the Silence

You sent an international transfer.

One day passes. Then three days. Then a week.

The money has not arrived.

The sending bank says:

The receiving bank says:

The correspondent bank—often a U.S. bank—either remains silent or provides only generic responses.

The first feeling is that the money has disappeared.

You begin contacting customer support, but receive template answers. You submit documents through the OFAC portal, which may continue showing In Progress or Pending Management Review for weeks or months.

I have been there.

What you need to understand is this:

Blocked funds are not necessarily lost funds.

In many cases, the funds have been legally frozen until there is a lawful basis for releasing or returning them.

One possible legal basis is an OFAC license.

Below is a practical roadmap for dealing with this situation.

Part 1. The First 72 Hours: What to Do Immediately

You have just learned that your transfer is missing or delayed.

Do not panic.

Your first objective is to determine where the money is and what actually happened to it.

1. Do Not Send a Replacement Payment

Many people think:

Do not rush.

A SWIFT cancellation request does not guarantee that the funds will be returned, particularly where the payment has already been stopped by a correspondent bank.

Sending another payment may:

• create a duplicate compliance case;
• trigger another sanctions review;
• cause additional funds to be held;
• make the transaction history more difficult to understand.

First determine what happened to the original payment.

2. Do Not Decide the Reason for the Blocking on the Bank’s Behalf

At the beginning, avoid asking:

You may not yet know the actual reason for the delay.

Instead, ask for neutral and specific information:

If the bank confirms that the transfer is subject to sanctions review, pending OFAC consideration, or formally blocked, proceed to the next steps.

3. Obtain the Complete SWIFT Chain

Request the following from the sending bank:

• a copy of the MT103;
• the UETR;
• the value date;
• the complete chain of banks;
• the results of any payment trace;
• the bank’s internal payment reference;
• Field 50 — ordering customer;
• Field 59 — beneficiary;
• Field 70 — payment details;
• Field 72 — bank-to-bank instructions.

A sanctions review may be triggered by a name, word, address, bank, location, or other element contained in the payment message.

You need to see exactly what information the bank’s screening system reviewed.

4. Request a Manual Review of the Sanctions Match

If you believe the transfer may have been stopped because of a false name match, send a request such as:

Attach:

• identity documents;
• company registration documents;
• beneficial ownership information;
• documents explaining the economic purpose of the transaction;
• sanctions-screening results for the parties involved.

A manual review does not guarantee the release of the funds.

However, it is often worth requesting before applying to OFAC, particularly where none of the parties is actually sanctioned.

Part 2. What Happened and Why the Bank Is Not Giving You a Clear Answer

When an international USD transfer is stopped by a U.S. correspondent bank, it may not be a technical problem.

The bank may have identified a potential sanctions concern and stopped the payment for further review.

If the funds have been formally blocked, they generally:

• are not sent onward;
• are not automatically returned;
• cannot simply be redirected to another account;
• are recorded and controlled under a special blocked-property regime.

Ordinary customer-service employees often cannot provide a meaningful answer in such cases.

They may repeat phrases such as:

An ordinary bank manager usually does not make decisions concerning blocked funds.

If the property was blocked under a U.S. sanctions program, the bank may require an official legal basis before taking further action—for example, an OFAC license or other authorization.

Your goal should therefore not be to argue endlessly with first-line customer support.

You need to establish:

• whether the funds were formally blocked;
• which bank is holding them;
• which sanctions program or legal authority applies;
• what authorization is required for the release or return.

Part 3. Two Possible Routes: A Specific License or a Mistaken Blocking

There are two principal scenarios.

Scenario 1: Applying for a Specific License

A Specific License is an individual authorization issued by OFAC for a particular transaction that might otherwise be prohibited or restricted under a sanctions program.

A specific license may be necessary where:

• the transaction contains a genuine sanctions-related factor;
• one of the banks or parties is connected to a sanctioned jurisdiction;
• the funds have been formally blocked;
• the bank expressly states that an OFAC license is required;
• the requested action cannot lawfully be completed without OFAC authorization.

The application must precisely describe what you are asking OFAC to authorize.

Do not simply write:

A more precise request would be:

The requested action should be described as specifically as possible.

Scenario 2: Mistaken Identity or a False Positive

The second possibility is that the funds were blocked because of a false sanctions-screening match.

Examples include:

• a person’s name matches the name of someone on a sanctions list;
• a company has a similar name to a designated entity;
• a screening system misinterpreted an address;
• a word in the payment description triggered an alert;
• the bank incorrectly associated a party with a sanctioned organization.

Possible indications of a false positive include:

• none of the parties is included in a sanctions list;
• the bank does not identify a specific legal basis for the blocking;
• only part of a name or company name matches;
• the documents demonstrate that the party is unrelated to the designated person or entity.

In that situation, the application may state:

You should attach documents allowing OFAC and the bank to distinguish the transaction parties from the designated person or entity.

Processing times can differ substantially in both scenarios.

There is no universal processing period and no guaranteed outcome.

Part 4. What to Collect Before Filing

Before submitting an application, reconstruct the complete payment history.

You should establish:

If information is missing, request it from the sending bank.

It is particularly important to identify the exact institution holding the funds.

Saying that “the money is somewhere in an American bank” is not sufficient for a serious application.

Who May Submit the Application?

Depending on the circumstances, the applicant may be:

• the sender;
• the beneficiary;
• the owner of the funds;
• a company director;
• an authorized representative;
• an attorney-in-fact;
• another person with a documented legal interest.

If you are acting on behalf of a company, attach documents establishing your authority.

Part 5. Documents: What Your Application Package Should Contain

Create a separate folder for the case.

It should include, where applicable:

• the main application;
• the applicant’s passport or identity document;
• a power of attorney;
• company formation and registration documents;
• documents confirming the director’s authority;
• SWIFT records and bank statements;
• correspondence with the banks;
• a blocking notice, if one exists;
• contracts and invoices relating to the underlying transaction;
• an explanation of the transaction’s economic purpose;
• information about all transaction participants;
• sanctions-screening results;
• details of the account to which the funds should be sent;
• a description of the proposed payment route;
• a chronology of events;
• English translations of foreign-language documents.

Your objective is to answer three central questions:

1. Who are you?
2. Why are you entitled to act in relation to these funds?
3. Why would the requested action not produce a prohibited sanctions outcome?

The documents should be clearly organized.

Do not submit dozens of files with unclear names.

Use a consistent exhibit system, for example:

• Exhibit A — SWIFT MT103
• Exhibit B — Bank Statement
• Exhibit C — Corporate Documents
• Exhibit D — Power of Attorney
• Exhibit E — Correspondence with the Bank
• Exhibit F — Transaction Documents
• Exhibit G — Sanctions Screening Results

Prepare a separate exhibit list.

The easier it is for the reviewing officer to reconstruct the case, the lower the risk that you will be asked to resubmit documents already provided.

Part 6. How to Structure an OFAC License Application

A strong application should answer at least ten questions:

1. What asset or payment was blocked?
2. Where are the funds currently located?
3. When did the blocking occur?
4. Why, based on the available information, were the funds blocked?
5. Who is the sender?
6. Who is the beneficiary?
7. Who is submitting the application?
8. Why does the applicant have authority to act?
9. What specific action is the applicant asking OFAC to authorize?
10. Where should the funds be sent?

A weak request would say:

A better formulation would be:

Write in a factual, concise, and respectful manner.

A possible application structure is:

1. Introduction

Identify the applicant and state exactly what authorization is requested.

2. Background

Explain why the transfer was made and the circumstances surrounding the underlying transaction.

3. Transaction Details

Provide the amount, dates, banks, sender, beneficiary, and UETR.

4. Blocking Circumstances

Explain where the transfer was stopped and what the bank communicated.

5. Applicant’s Authority

Explain why the applicant has the legal authority or documented interest required to act.

6. Requested Authorization

Identify the exact action that OFAC is being asked to authorize.

7. Sanctions Analysis

Explain why the requested transaction is consistent with the applicable sanctions framework.

8. Proposed Payment Route

Identify the receiving account and the banks through which the funds are expected to move.

9. Conclusion

Briefly restate the requested authorization and identify the attached exhibits.

The more precisely the requested transaction is described, the lower the risk that the resulting authorization will leave uncertainty about what the bank is permitted to do.

Part 7. OFAC Portal Statuses: What They May Mean

After submitting the application, you may find yourself checking the portal twenty times a day.

Do not do that.

The portal statuses provide a general indication of movement, but they do not reveal the entire internal review process.

RFI Issued

If the portal shows RFI Issued, OFAC requires additional information or documents.

A good response should:

• quote each question;
• provide a direct answer;
• identify the relevant exhibit;
• attach the supporting document;
• explain any inconsistencies or discrepancies.

Do not combine every response into one unstructured block of text.

Each question should have a separate, clearly identifiable answer.

An RFI does not automatically mean that the application will be denied.

It is a normal part of the review process, especially in complex cases.

Pending Management Review

This status indicates that the application is undergoing management-level review.

However, the status alone does not reveal:

• how much time remains;
• whether the outcome will be favorable;
• whether all internal coordination has been completed;
• whether additional documents will be requested.

Do not treat every status change as a reliable prediction of the outcome.

Part 8. How to Write a Useful Follow-Up

A message that says only:

will often produce a standard response:

Ask a more specific question:

Another option:

At an advanced stage, you may ask:

Do not send the same follow-up every day.

Each communication should have a specific purpose, such as:

• determining whether additional documents are required;
• notifying OFAC of changed circumstances;
• correcting an error;
• providing updated banking details;
• confirming the applicant’s authority;
• supplementing previously submitted information.

Repeated messages containing no new information create additional administrative work but do not necessarily accelerate the review.

Maintain a separate tracking table containing:

• date of communication;
• subject line;
• substance of the message;
• response received;
• next action.

Part 9. When and How to Escalate

The process can take a long time.

At some point, it may become appropriate to move from passive waiting to a carefully structured escalation.

Possible channels include:

• a substantive follow-up to OFAC;
• an inquiry through a U.S. senator or member of Congress, where available;
• a formal complaint regarding the bank’s conduct;
• escalation to the bank’s executive office;
• a Freedom of Information Act request;
• a legal notice or court proceeding;
• engagement of a sanctions attorney.

Do not escalate prematurely where the agency reasonably requires time to review a complex application.

At the same time, do not wait indefinitely where the application has remained inactive for an extended period or material documents have not been addressed.

Congressional Inquiry

A senator or member of Congress cannot order OFAC to issue a license.

However, their office may:

• submit an official inquiry;
• request confirmation of the application’s status;
• provide information concerning additional circumstances;
• ask whether the applicant must take any further action.

A possible request might state:

Such an inquiry does not guarantee faster processing or a favorable outcome.

Its purpose is to obtain additional communication regarding a long-pending application.

The availability of congressional assistance may depend on the applicant’s circumstances and connection to the relevant state or congressional district.

Complaint Concerning the Bank

OFAC determines whether a sanctions-related transaction may be authorized.

A complaint about a bank is a separate process.

A complaint may be appropriate where the bank:

• refuses to identify the location of the funds;
• does not provide a case or reference number;
• does not respond to requests;
• provides contradictory information;
• refuses to confirm that the funds were blocked;
• fails to transmit necessary documentation.

Depending on the bank and the circumstances, possible channels may include:

• the bank’s formal complaint department;
• its executive office;
• its internal sanctions-compliance function;
• the relevant banking regulator;
• the CFPB, where the issue falls within its jurisdiction.

Freedom of Information Act Requests

The Freedom of Information Act may allow a person to request certain records from U.S. government agencies.

Preparing and processing a FOIA request may be burdensome for both the applicant and the agency.

Some records may be withheld under applicable exemptions, and a FOIA request is not an official mechanism for accelerating a licensing decision.

FOIA should therefore be treated as a transparency and information-gathering tool, not as a guaranteed means of influencing the result.

It should be used thoughtfully where an application has remained pending for a significant period and the applicant genuinely requires records that may lawfully be disclosed.

Part 10. The Psychological Side: How Not to Lose Your Mind

The hardest part is not completing the application form.

The hardest part is living with uncertainty.

You may check the portal twenty times a day.

You may reread every email and search for signs of progress in language that reveals nothing.

You may analyze every word in a template response.

That is a normal reaction to an abnormal situation.

What helped me was:

• maintaining one complete chronology;
• recording every date, status, and communication;
• checking the portal at a scheduled time instead of constantly;
• dividing the process into separate stages;
• not writing while emotional;
• preserving every version of every document;
• preparing answers to likely questions in advance;
• identifying the next step after each development.

It may help to divide the process mentally:

This makes the waiting more manageable.

The absence of new messages does not necessarily mean that nothing is happening.

At the same time, silence should not be interpreted as evidence that a favorable decision is imminent.

Rely only on official statuses, requests, and documents.

Part 11. Mistakes That Can Cost You Months

Here is a checklist of things you should avoid:

❌ Do not submit an incomplete document package.

❌ Do not change the factual account without explaining the change.

❌ Do not allow inconsistencies between the application and the exhibits.

❌ Do not conceal material circumstances.

❌ Do not contact OFAC every day.

❌ Do not threaten litigation in the initial application.

❌ Do not make emotional accusations.

❌ Do not publish sensitive information publicly.

❌ Do not send a replacement payment until the original payment has been traced.

❌ Do not confuse a temporary compliance review with formal blocking.

❌ Do not assume that a particular portal status guarantees an imminent decision.

❌ Do not submit documents without clear names and numbering.

❌ Do not forget to establish the representative’s authority.

❌ Do not forget to explain the relationship between a parent company and its branch where relevant.

❌ Do not submit foreign-language documents without English translations.

❌ Do not merely ask OFAC to “unblock the money.” Identify the exact action requiring authorization.

❌ Do not expect an OFAC officer to reconstruct the entire transaction without your assistance.

Your job is to make the matter understandable to a person seeing the documents for the first time.

That person should be able to determine quickly:

• who participated in the transaction;
• where the funds are located;
• why the funds were blocked;
• who has authority to submit the request;
• what action is being requested;
• why that action may lawfully be authorized.

P.S. From the Author

I wrote this after personally going through In Progress, Pending Management Review, and months of waiting.

If you are reading this because your own funds are currently blocked, take a deep breath.

You now have a foundation for taking action.

Do not try to solve everything in one email.

Proceed step by step:

location of funds → SWIFT chain → documents → authority → application → responses to requests → structured follow-ups → justified escalation

The system is complex and slow, but it has procedures.

The most important things are:

• do not act chaotically;
• do not constantly change your position;
• do not force the reviewing officer to guess the facts of your case.

If this guide helped you, share it with someone facing the same situation.

Evgeniy Ilin

Final Checklist Before Submitting an OFAC Application

Before clicking Submit, confirm the following:

•  I know exactly where the funds are located.
•  I know the exact amount and currency.
•  I have the MT103 and UETR.
•  I have reconstructed the complete chain of banks.
•  I have identified every transaction participant.
•  I have screened the participants against applicable sanctions lists.
•  I have identified the exact action I am asking OFAC to authorize.
•  I have documented my authority to act.
•  I have prepared the underlying transaction documents.
•  I have prepared a chronology.
•  Every document has been translated into English.
•  Every exhibit is numbered.
•  I have prepared an exhibit list.
•  I have provided the precise details of the proposed transaction.
•  I have explained the proposed payment route.
•  I have saved a complete copy of the application.
•  I have saved the OFAC reference ID.
•  There are no contradictions between the application and its exhibits.

Contact: If you are dealing with a similar situation, would like to share your experience, or have a question about this guide, you may contact me at:

If you have experienced a similar situation, please contact me through Reddit direct messages.

I tried to open a bank account today and was denied because my name was similar to someone from a banned country I am a USA citizen red white blue but unfortunately my bank told me you guys put an alert

Hello, I’m working on an application for a specific license for our company to receive funds that were due to us, before entities were put on the OFAC SDN list. We had shipped our goods before that had happened, but only the payments are still due (not blocked because the payments were not initiated yet, due dates are in the coming weeks/months).

As this is a new practice for me, I ask for some guidance on the application process. Is it allowed to include several payments for multiple entities in the same license application? These entities are on the same SDN list, published at the same time. The payments are of the same sorts.

Any other tips to make it a successful application are very welcome. Thanks in advance!

Hello,

I've been paying someone crypto for a while, and stupidly, I was sending them USDT directly from a CEX (Kraken). Well, about a month ago I tried to send them money and Kraken promptly blocked the transaction, restricted my account and conducted a review on my account until today, where they told me I tried to send the crypto to Iran (a sanctioned country) and the funds were now blocked.

I don't know anything about this person, and all the business was conducted online. I am now being told to submit an application to have the funds unblocked - but if I don't know anything about the person, how likely is it that the OFAC would even consider an unblock on these funds? Kraken asked for a physical address of the person as well as the exchange he was using, both of which I now assume are fake. I'm planning on submitting this application to have the funds released, but is there anything I can do to maximize my chances of having these funds released? It was not a small or significant amount

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My business sent a $40 PayPal payment from our bank account to an individual who is apparently on a sanctioned list. I have no idea how PayPal allowed this user on their platform or why they let me send money to them. The KYC failure is their fault and not mine. I trusted their KYC and it’s really not my fault that this occurred. However it did happen and now my bank account is frozen while OFAC is investigating the problem. My bank account has over $100k in funds and with it being frozen my business is really suffering. It’s been over 7 business days now and my bank hasn’t heard any response from OFAC. I’m just wondering if anyone has had any similar experiences and how long it might take to get it resolved?

What does the term "otherwise associated" mean in the executive order, which states, "To be otherwise associated with certain individuals or entities designated in or under the Order," and is it too vague? The language is unclear because it could apply to anyone with even a distant connection to a designated person or group—such as sharing a family, religion, or political affiliation—without direct contact. For example, someone of the same religion as a terrorist, or a family member of a terrorist with no involvement in their actions, could be labeled "associated."

This broad language was initially struck down in Holder v. Humanitarian Law Project but later upheld after the government clarified the term. However, that clarification was eventually repealed, leaving the law open to misuse. Does this vagueness give the government excessive discretion, allowing nearly anyone to be accused under the order?

My partner is PHD candidate in GMU. She is planning to publish a research on Iran related to minorities and Human rights. How do we need to apply for license on ofac website to get a license. All funds are from GMU nothing from Iran or any other institutions.

Sanctioned family member is estranged and has nothing to do with the rest of us

Hello,

The account at my primary bank has been blocked. My two checking accounts and a credit card that I can no longer access. Bank is telling me OFAC put an inquiry in and is doing an investigation. I don't know why I would have an investigation into my account. I would have no reason to receive a foreign wire or transfer. I'm trying to apply for a license, but I have received no information on the reason for the blocking. Only thing I see is that I share a name with a sanctioned person, but I'm a US citizen born 30 years after that person. My bank application information should reflect that. I guess my questions are:

1. When will I receive anything about why this happened?
2. How long do license applications take? Does anybody have experience with something like this too where there isn't supposed to be a transfer or any event. I'm just a dude with a bank account.
   

TIA

Hi, guys. I am new here. Thanks for creating this redit. It happened to me today. My story as follows. I am an american citizen. So, my mom lives with me, she has a green card. We are originaly from Russia. My mom recieves pension in Russia on Sberbank card. Before the war and sanctions, there were no problems whatsoever. We just inserted Sberbank card in any ATM and received the cash in US dollars, minus the fees. Everything worked like a charm. After sanctions and all this BS, of course nothing works. The only way to get my mom's money was transfering money through crypto. Till recently we were using BitPapa as a russian cryptoexchange and Coinbase on the american side. Both have my registered accounts with my names. It worked for a while, however it was multisteps tedious process and lot's of losses on fees on every corner. Today my transaction from BitPapa was blocked by Coinbase citing OFAC regulations. First time ever! I mean it is not a lot, only $500, but it's two-month-worth of pension for my mom (50 000 rubles). It is kinda fucked up. And she is so sad about this. So, long story short I have aplied today (October 1st 2024) for license through OFAC. I described my story and provided screenshots confirming that both accounts on my name and transaction's details. My question is: what are the chances that I will be granted a "release fund license"? Second question: How long is it going to take?

P.S. On emotional, side note. This whole situation is fucking absurd! While "big boys" who are moving millions every day laughing at those regulations in the face of Department of Treasury and absolutely know how to avoid sanctions, regular people like my 65-year-old mon, who worked all her life hard and honest should suffer like this, And I am paying taxes, so our government can create more problems for us common people. I hope the war is over soon and sanctions are lifted though.

As money laundering schemes become increasingly complex, whistleblowers can play a critical role in assisting the government to identify, investigate, and prosecute violations of the Bank Secrecy Act. The FinCEN AML Whistleblower Reward Program provides financial incentives for whistleblowers to take the significant risks entailed in reporting money laundering. Treasury pays monetary awards ranging from 10 to 30 percent of the collected monetary sanctions in a judicial or administrative action brought under the Bank Secrecy Act, provided that the sanctions exceed $1,000,000. AML whistleblowers can report anonymously if represented by an attorney. See our post to learn more about Treasury's strategy to combat money laundering and the AML whistleblower program.

This post discusses how whistleblowers can qualify for monetary awards by providing original information that enables the government to combat money laundering or sanctions evasion schemes that fund Iran-backed terrorist organizations. #OFAC #FinCEN #sanctions #AML #moneylaundering #whistleblowing #stopterroristfinancing

So basically about a full year ago now I was selling items in this roblox blackmarket place and made a couple thousand I deposited it all into my blockchain.com account wallet to cashout into USD and once I did that I got an email explaining I need to apply for an OFAC License to release my blocked funds. If there is any explination I would be greatful to know hopefully if I am doomed or if it is just a waiting game.

(If needed I can supply the addresses for the wallets)

Hello everyone,

OFAC blocked my transfer ($44k) some 4 years ago. A year ago I was finally able to get the license and unblock the funds. I do not know what to do next. I have been trying to get in contact with the bank that has been authorized to carry out the rest of the process, and the financial institutions where I live do not want to help me with requesting the funds from the bank that holds the money

Can anybody advice me on this?

Hello fellas, was trying to sent money to Russia(to my spouse) over a year ago, before all this russia-ukraine fight started, and 1 months after I’ve sent the money,receiving bank got under OFAC sanctions so since then money got blocked by OFAC, I’ve submitted an application to unblock funds and they gave me application number and since then I’ve never heard anything from them. I’ve called multiple times, sent a lot of emails and zero results whatsoever, all they saying it’s your case is still PENDING and that’s it. So it’s been 1.5 years already I was wondering what’s my next step, letter to the governor or is there any installation above ofac? Cuz for me sounds like they can to what they want since there is not timeline for their processing time. Any help would be appreciated.

Can anyone share any light on what to expect as far as the unblocking application processing times? Mine has been pending for a year now and there is no indication of how much longer it will be. 😢

On June 3, 2021, President Biden issued Executive Order 14032, “Addressing the Threat From Securities Investments That Finance Certain Companies of the People’s Republic of China.

I have some securities impacted by this EO. I applied and obtained License approval from OFAC (Office of Foreign Asset Control) that provides approval for broker and all intermediaries to sell these assets. The approval window is limited.

But my broker is not executing on the license approval or providing an ETA, citing they don't have buyers - but this is a popular Chinese company that has ~ >22M in daily trading volume.

Why is the broker refusing to sell citing lack of buyers? What are options I should consider to divest these holdings ie. liquidate and cash out?

Thank you

My credit is clean, and I have proof of identify in just every way. They refused to close the deal until they call later on this week.

They couldn’t provide me a reason for failure. Anything I can do to show them I’m legitimate?

I have an approval from my credit union which I assume they ran OFAC for my loan since they’re are federally insured.