OFAC General License Glossary Part 1

What an OFAC general license is, and how it changes what transactions are permitted.

TL;DR

TL;DR: A general license is an OFAC authorization that permits a category of transactions that would otherwise be prohibited, without the need for a specific application. It is published and applies automatically to anyone who meets its conditions.

What a general license is

OFAC, the Office of Foreign Assets Control, issues general licenses to authorize transactions that sanctions would otherwise block. Unlike a specific license, which a party must apply for, a general license applies to everyone who meets its stated conditions and is published in the regulations.

Why general licenses matter

A transaction that falls within a general license is not a violation, even if it involves a party or activity that sanctions otherwise restrict. But the coverage is narrow, and the conditions must be met exactly. Because OFAC enforcement is strict liability, assuming coverage that does not exist still leaves a party exposed to penalties starting at $356,000 per violation.

General licenses and agent payments

An AI agent should not guess whether a payment is covered by a general license. The safer path is to screen first: the sanctionsai.dev API checks a counterparty before payment and returns ALLOW or BLOCK in under 100 ms. Not documented: any general license determinations the product performs automatically.