It has been brought to our attention that many individuals are routinely mistaking a “return-without-action” letter from OFAC for an OFAC license. Please be advised that a one page letter or response from OFAC is often a RWA Letter and not an actual license. This is merely a correspondence from OFAC. This IS NOT an OFAC license and will not be treated as such by your bank or by OFAC should any problems arise with the underlying transaction(s).

Furthermore, when an OFAC license is submitted to the government, OFAC will routinely issue a case number for that application for reference purposes. This is so one can easily reference the case when calling or writing to OFAC to check the status of the application and/or to submit any needed supplemental information. Once again, a case number IS NOT an OFAC license number and will not be treated as such by your bank or by OFAC.

Please be advised that this type of letter is also routinely sent in response to a license application submission in which the applicant is asking OFAC for authorization to engage in activities that are ALREADY authorized by GENERAL LICENSES, such as the receipt of Non Commercial Personal Remittances from Iran or the Sale of Property in Iran.  A “return-with-no-action” letter can also be sent if an application is missing certain information thereby preventing OFAC from being able issue a final decision.

An actual OFAC license will have a license number as well as an expiration date. It will also clearly outline the authorized activity. For a sample OFAC license, please clink the following link: Sample License

If you received a return-without-action letter and would like additional guidance regarding this matter, please feel free to contact our firm at 310-780-6360 or email us via our website’s contact page.

 

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