OFAC False Positive: $100K Wire Transfer Unblocked in Weeks

The OFAC Lawyers at Sanctions Law Center are excited to announce a favorable decision on an unblocking application that was filed just weeks before the specific license was granted.

Our client was expecting a wire transfer from his relative in Mexico City, but the transfer was blocked in mid-2023 because of a mistaken match with a sanctioned Venezuelan official with a similar name. Our client’s relative, who recently retired from a 40 year career with a significant Mexican university, has no ties to Venezuela or the government in Caracas. The blocked funds, amounting to nearly $100,000, have significantly impacted our client’s quality of life and financial stability.

The case of our client is considered an OFAC false positive, where the name of the individual is similar to a sanctioned individual’s name, but the rest of the information provided by the applicant does not match the descriptor information on OFAC’s SDN List.

An unblocking application is a formal request submitted to OFAC seeking the release of assets frozen under U.S. sanctions programs. Assets linked to parties sanctioned by OFAC can be frozen and placed into a secure account by U.S. entities, and once frozen cannot be moved without permission from OFAC.

OFAC unblocking applications take on average 6-30 months to be assessed, and vary depending on the complexity of the case. However, our attorneys pursued a unique and effective strategy to earn a favorable outcome for our client with an uncharacteristically fast turn-around time.

After confirming that neither our client nor his relative was subject to OFAC restrictions, the OFAC Lawyers at Sanctions Law Center assembled an unblocking application proving that this was a case of mistaken identity with no lawful basis to continue blocking the funds. We simultaneously pursued a unique outreach strategy to ensure our client obtained an expeditious unblocking of their funds. Just weeks after submitting the application, we received OFAC’s written response that notified us that the funds were unblocked in full.

OFAC sanctions compliance can feel complex and daunting, but with the right strategy, even blocked assets can be recovered. This case is a reminder that proactive advocacy and a clear presentation of facts can lead to favorable and timely resolutions.

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) 914-1545 here to schedule a consultation.