Spanish notaries and property registrars do not directly enforce OFAC sanctions, but practical obstacles arise immediately. Spanish banks will refuse to process purchase funds or mortgage payments involving designated persons. Title insurance companies with US affiliations will decline coverage. Buyers and their legal counsel routinely screen sellers against OFAC lists, making sales nearly impossible without delisting or a specific licence. You retain legal ownership of existing property, but transferring, mortgaging, or selling becomes functionally blocked. An OFAC specific licence can authorise discrete real estate transactions while delisting proceedings continue.
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