OFAC Unblocking Success: $600K Released for Healthcare Company

The OFAC Lawyers at Sanctions Law Center are pleased to announce a favorable decision on a specific license request filed on behalf of a healthcare company. OFAC granted a specific license to the Client authorizing the release of over $600,000 in blocked funds. The unblocking application was filed just four months before receiving the favorable decision.

Our client operates a network of healthcare centers in Russia and is engaged in the business of trading medical equipment, mostly in relation to its network of renal care treatment centers. While trying to execute a wire transfer intended to prepay for essential equipment from a key supplier, they were subjected to an unexpected blocking due to the recipient bank’s recent designation to the SDN List. The blocking had significantly impacted our client’s ability to provide life-saving renal care to primarily indigent patients, and the release of those funds were key to continuing

An OFAC unblocking application is a formal request seeking the release of assets that have been frozen under U.S. sanctions programs. When OFAC imposes sanctions, assets linked to those sanctioned entities may be frozen by U.S. financial institutions or businesses. These assets cannot be moved, withdrawn, or used without proper authorization from OFAC.

The length of time it takes for OFAC to process an unblocking application can vary widely depending on the complexity of the case, on average taking 6-18 months to review and assess the case. However, through our sanctions attorneys’ government-relations advocacy, the case received expedited review and resulted in a favorable outcome with an unusually fast turnaround.

Though this was a lawful and legitimate blocking due to the involvement of a sanctioned interest in the commercial transaction, we were able to argue unique and compelling circumstances to obtain an unfreezing of our client’s assets. OFAC’s general policy is to only license the unblocking of funds in cases of a mistaken identity or another kind of erroneous block, unless there are compelling circumstances at play. We were able to persuade OFAC that unblocking the funds in this case was consistent with U.S. foreign policy goals because our client lends critical medical treatment to indigent or elderly patients in Russia.

This victory underscores our OFAC Lawyers’ commitment to achieving favorable decisions on behalf of our well-meaning clients— even in the face of a lawful blocking of funds.

About Sanctions Law Center

This action highlights the importance of implementing and adhering to a well-designed sanctions program, as well as cooperating with OFAC when any compliance issues arise. The OFAC Lawyers at Sanctions Law Center have years of experience helping our clients craft compliance programs and navigating OFAC investigations. Whether you need help dealing with compliance issues or preventing them from arising in the first place, our OFAC Lawyers can help. Contact us today or call (202) 888-9011 here to schedule a consultation.