By ยท ยท last updated 2026-08-07

What Happens After a Payment Is Blocked

The post-block workflow: record, review, report. What OFAC expects within 10 days, and how the audit trail turns a block into evidence.

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A blocked payment is the system working. What happens next determines whether the block becomes compliance โ€” or a problem.

Step 1: Record

Every block is logged with the matched list entry, the list version, and the timestamp. This is the evidence โ€” it must exist before anything else.

Step 2: Review

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Confirm the match is a real hit, not a false positive. Identifier comparison, ownership checks, and the 50% rule all apply. Document the decision.

Step 3: Report

For real hits, OFAC expects a blocking report โ€” typically within 10 days of the block. The blocked-transaction template has the structure.

The asymmetry

A block costs minutes. A release of a real hit costs $356,000 and starts at the base penalty. The block is not a failure โ€” it is the product working.

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