May a debit to an account of a person blocked pursuant to Executive Order (E.O.) 14024 be authorized as a transaction that is ordinarily incident and necessary to a licensed transaction?
OFAC's answer
An authorization for transactions that are ordinarily incident and necessary to a transaction licensed pursuant to [E.O. 14024](https://ofac.treasury.gov/media/57936/download?inline) does not implicitly authorize a debit to a blocked account on the books of a U.S. financial institution. Debits to an account on the books of a U.S. financial institution of a blocked person are only authorized as transactions ordinarily incident and necessary to a licensed transaction if such license explicitly authorizes such debits. For example, General Licenses (GLs) [9](https://ofac.treasury.gov/media/918666/download?inline) and [10](https://ofac.treasury.gov/media/918671/download?inline) explicitly state that debits to accounts on the books of a U.S. financial institution of the blocked entities listed in the GLs are authorized to the extent ordinarily incident and necessary to effect the specified transactions authorized therein. By contrast, GLs 3 and 11 do not explicitly authorize debits to accounts on the books of a U.S. financial institution of the blocked entities.