Should financial institutions apply for a specific license to unblock funds transfers or accounts which meet the conditions for unblocking set forth in 31 CFR §§ 515.505, or 515.584 (e)?
OFAC's answer
The CACR include a general license authorizing banking institutions to unblock any account that had been previously blocked solely because of the interest therein of one or more persons now licensed as unblocked nationals. For a complete description of what this general license authorizes and the restrictions that apply, see [31 CFR § 515.505(b)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.505). The CACR also include a general license at [31 CFR § 515.584(e)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.584) that authorizes the unblocking and return of funds transfers that could have been processed pursuant to 31 CFR §§ [515.562(b)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.562) or [515.579(b)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.579), if the processing of those transfers would have been authorized by the current text of the general licenses. Funds unblocked pursuant to [31 CFR § 515.584(e)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.584) that were originally blocked on or after August 25, 1997 must be reported to OFAC. For a complete description of what this general license authorizes and the restrictions that apply, see [31 CFR § 515.584](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.584). If your situation appears to meet the requirements of these general licenses, OFAC suggests that you contact the financial institution maintaining the blocked account or blocked funds transfer to request that it review your situation within the context of the terms of the appropriate general license. If the terms of a general license apply, there is no need to seek specific license authorization from OFAC. It is OFAC’s policy not to grant specific licenses authorizing transactions for which the provisions of an outstanding general license are applicable. See [31 CFR § 501.801(a)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-H/section-515.801).