Before you apply for a licence, know the sanctions risk you are carrying.

What it is and why you are asked for it

A specific licence is a non-public document issued to a particular person or entity for a particular transaction, on application (31 CFR 501.801(b)). It is only the answer when no general licence covers the transaction: OFAC’s stated policy is not to grant specific licences for what a general licence already covers (31 CFR 501.801(a)).

What this service includes

• Confirming first that no general licence applies.
• The application through OFAC’s licensing portal — unofficial channels delay the case, OFAC warns.
• A fact-focused narrative with the full names of every party involved or interested, as the rule requires.
• The supporting documents, with an English translation of anything in another language.
• Answering OFAC’s requests for information and following the case by its Case ID.

What it does not include

• The licence itself. OFAC can deny: DENIED and RETURNED WITHOUT ACTION are published outcomes, and there is no right to a licence.
• A decision date, because OFAC publishes none.
• Reconsideration after a denial, which is possible on new facts but is a new piece of work, not an appeal.

What we need from you

• A detailed description of the purpose of the transaction.
• Names and addresses of every party.
• Identification, invoices and contracts.
• Relevant dates and a contact.
• To unblock funds: the bank’s prior confirmation that they are blocked, and the OFAC Reporting System identifiers.
• For renewals, 60 to 90 days’ notice.

How long it takes

OFAC publishes no deadline. Applications are reviewed case by case, generally in order of receipt, and the time depends on whether OFAC asks for more information, consults other agencies, or on its volume. The clock is OFAC’s, not ours and not yours. The published statuses — received, in progress, pending with applicant, pending interagency review and the rest — explain the wait.

What moves the licence figure

• The sanctioned country involved
• The type of licence needed
• Whether there is a US nexus
• How complex the corporate structure is — including tracing ownership under the 50% rule
• How many sanctions programmes are engaged

Price

USD 8,000 to USD 32,000

What it is and why you are asked for it

A screening and risk analysis of a specific transaction against US sanctions: who is on which list, what the ownership chain hides, which programmes touch the deal and which general licences may be relevant. It serves two measurable purposes: reducing the risk of liability under 50 U.S.C. § 1705, and not filing an application you may not need — OFAC does not grant a specific licence for what a general one already covers.

What this service includes

• Identifying the US nexus (OFAC FAQ 11).
• Screening every party against the SDN list and the consolidated lists.
• Applying the 50% rule through the ownership chain: an entity owned 50% or more, directly or indirectly, by blocked persons is itself blocked even if it is on no list.
• Identifying which sanctions programmes apply and what they prohibit.
• Identifying the general licences that may be relevant and listing their conditions, including registration and reporting.
• A written risk assessment: the level of risk, what drives it and what would reduce it.

What it does not include

• A legal conclusion that the transaction is permitted or prohibited. If you need one, tell us before we start.
• Any authorisation. A private assessment does not bind OFAC and authorises nothing: only an applicable general licence or an issued specific licence does.
• An OFAC legal opinion, which OFAC does not issue. What it does issue on request is interpretive guidance, which we can prepare separately.

What we need from you

• The full identity and jurisdiction of every party, intermediary and final beneficiary.
• The ownership structure, with percentages.
• The nature, value and currency of the transaction, and the goods or services and their origin.
• Payment routes and banks, and the countries of origin, transit and destination.
• Contracts, and any previous dealings with the same parties.

How long it takes

Controlled by us, and it depends on what you provide. OFAC does not take part, so no OFAC deadline applies.

Price

USD 2,500

What it is and why you are asked for it

OFAC does not impose a programme of set content on everyone, but whether a company has an adequate risk-based compliance programme is one of the factors it weighs when deciding administrative action (Economic Sanctions Enforcement Guidelines, 31 CFR Part 501, Appendix A), alongside intent, knowledge, harm, size and sophistication, remediation and cooperation. And voluntary self-disclosure halves the base amount of a penalty.

What this service includes

• The programme built on OFAC’s Framework for Compliance Commitments, whose five pillars are the index of what you receive:
• Management commitment: review and approval by senior management, delegated authority, resources, and a culture of compliance.
• Risk assessment: periodic, across customers, products, services, supply chain and geographies, with a method to identify and treat what it finds.
• Internal controls: written policies and procedures to identify, stop, escalate, report and record potentially prohibited activity.
• Testing and audit: an independent function that evaluates whether the programme works.
• Training: at least annual, adapted to role, risk and geography.

What it does not include

• OFAC’s approval, certification or validation of the programme. None exists, and there is no official way to obtain one.
• Any authorisation: having a programme permits no transaction. It is a mitigating factor OFAC may weigh if there is ever a case, not a shield, and OFAC guarantees no reduction.

What we need from you

• Organisation chart and group structure: parent, subsidiaries and branches.
• Geographic reach, and your products with any US-origin content or technology identified.
• Your customers and counterparties, payment flows and banks.
• Existing policies, your screening tool and its configuration.
• Your history of alerts, blocks, rejections, infringements or self-disclosures.
• Headcount, training given, and previous internal audits.

How long it takes

Controlled by you and us. It is not a filing with the agency: there is no submission and no approval, and OFAC publishes no deadline. The Framework fixes only annual training and updating the risk assessment when breaches are found.

Price

USD 3,000