If I am delisted by OFAC, will Spanish banks automatically restore my accounts?

Not automatically. Spanish banks conduct independent compliance assessments and may maintain internal restrictions even after OFAC delisting. You will need to provide the official delisting notice from the Federal Register, updated due diligence documentation, and potentially a legal opinion confirming your status. Banks often require 30–90 days to complete internal reviews before restoring services. If the bank’s correspondent relationships were affected or reputational concerns remain, they may decline to resume the relationship entirely. Proactive engagement with the bank’s compliance department, supported by legal counsel, significantly improves restoration outcomes.