Yes. OFAC issues specific licences authorising otherwise prohibited transactions with SDN-listed parties under 31 C.F.R. Part 501. Common grounds include payment of legal fees, humanitarian transactions, wind-down of pre-existing contracts, and family maintenance. Licence applications must detail the transaction, parties involved, and justification. Processing times vary from weeks to several months. Licences are discretionary — OFAC denies applications that would undermine sanctions policy objectives. General licences published in programme regulations may also authorise certain categories of transactions without individual application, though these are narrowly defined and must be carefully reviewed for applicability.
Need Legal Help?
Facing an Interpol Notice or Extradition Threat?
Our international criminal defence lawyers have helped clients in 50+ countries. Get a confidential consultation today.