OFAC Blocked Property Glossary Part 1

What blocked property is under OFAC sanctions, and how the 50 Percent Rule extends it.

TL;DR

TL;DR: Blocked property is any property or interest in property in which a blocked person has an interest, and it must be frozen, not paid. Under the 50 Percent Rule, entities 50 percent or more owned by a blocked person are also blocked.

What blocked property is

Blocked property is defined by OFAC, the Office of Foreign Assets Control, as property and interests in property in which a blocked person has an interest. When property is blocked, it cannot be transferred, paid, or withdrawn without an OFAC authorization such as a general license.

Why blocked property matters

A payment to a listed person or a listed wallet turns the funds into blocked property the moment the transaction occurs. Because enforcement is strict liability, intent is not required, and the violation carries a civil penalty starting at $356,000 per violation. Prevention is the only way to avoid this outcome.

Blocked property and agent payments

The sanctionsai.dev API screens a counterparty before an agent pays and returns ALLOW or BLOCK in under 100 ms, so funds are never sent to a blocked party in the first place. It covers 19,218 SDN names and 947 OFAC-listed crypto wallets. Not documented: any mechanism to recover funds already sent to a listed wallet.