Can funds be withdrawn from the RECIPIENT ACCOUNT or a SPECIAL PURPOSE ACCOUNT?
OFAC's answer
In order for the National Defense Authorization Act's ([NDAA](https://ofac.treasury.gov/media/5761/download?inline)) [significant reduction exception](https://ofac.treasury.gov/faqs/254) to apply on or after February 6, 2013, funds withdrawn from the RECIPIENT ACCOUNT or [SPECIAL PURPOSE ACCOUNT](https://ofac.treasury.gov/faqs/260) at the [FFI](https://www.ecfr.gov/cgi-bin/text-idx?SID=f001609e54e2c4adcbab5dafe63ba4a7&mc=true&node=se31.3.561_1308&rgn=div8) may only be used to pay for bilateral trade or purchases relating to the Humanitarian Exception. Cash withdrawals from the RECIPIENT ACCOUNT or SPECIAL PURPOSE ACCOUNT would be deemed to fall outside of the scope of bilateral trade and would expose the FFI to sanctions. Bank checks written on the account may be used only to pay for bilateral trade or purchases relating to the Humanitarian Exception, and are subject to further restrictions set out in [FAQ 263](https://ofac.treasury.gov/faqs/263) below.