OFAC Licensing

An OFAC license is a written authorization from the Office of Foreign Assets Control that permits a transaction or activity that would otherwise be prohibited under US sanctions regulations. Licenses come in two forms: general licenses (published, applies to anyone) and specific licenses (issued to a particular applicant for a particular transaction).

General licenses

General licenses are published by OFAC in the Federal Register and authorize categories of transactions without requiring an application. Examples include licenses for humanitarian aid, personal remittances, legal services, and certain internet-based communications. If your transaction falls within the scope of a published general license, you do not need to apply — the authorization is automatic.

Specific licenses

Specific licenses are issued to individual applicants for particular transactions. You apply to OFAC's Licensing Division with a detailed description of the proposed transaction, the parties involved, and the legal basis for the license. Processing times vary from weeks to months depending on complexity.

When you need a license for agent payments

For AI agent operators, the most common licensing scenarios include:

• Unblocking frozen funds: If your agent's transaction was blocked in error, you apply for a license to release the funds.
• Pre-existing contracts: If you had a contract with a party before they were designated, a wind-down license may permit completing or terminating it.
• Legal fees: General License D authorizes payment of legal fees from blocked funds in many cases, without requiring a specific license.