What is the OFAC licensing process?

OFAC licenses authorize otherwise-prohibited activity; specific licenses require an application, while general licenses do not.

TL;DR

TL;DR: Apply through OFAC's online portal with a detailed description of the proposed transaction. Processing takes weeks to months. General licenses do not require an application.

General vs specific licenses

OFAC issues two kinds of licenses. General licenses authorize categories of activity automatically, without an application, as long as the activity fits the stated terms. Specific licenses authorize one particular transaction or party and require you to apply and be approved first. Knowing which kind applies is the first step before you engage in activity that might be restricted.

How to apply for a specific license

Submit an application through OFAC's online licensing portal. Describe the proposed transaction, the parties involved, and why the activity is justified, including any humanitarian or other grounds. Processing typically takes weeks to months, and the transaction should not proceed until the license is granted. OFAC does not guarantee approval.

Where screening fits

• Screen first to confirm whether a license is even needed.
• Do not proceed on the assumption a license will be granted.
• Keep the license and the screening record together for audits.

A license is an exception, not a default; screening tells you when you need one.

Before applying, screen the counterparty to confirm whether the transaction is actually restricted; many proposed transactions are not, and a license is only needed for the ones that are.