INTERNATIONAL TRADE LAW
OFAC Licenses: How to Apply and Qualify
An OFAC license is permission from the Treasury Department’s Office of Foreign Assets Control to engage in a transaction that U.S. sanctions would otherwise prohibit. If your deal touches a sanctioned country, person, or activity, a license is often the only lawful way forward. The threshold question is whether a general license already covers what you want to do, or whether you need to apply for a specific license. This guide explains the difference, walks through the application, and flags what makes an application succeed.
Before you apply, confirm you actually need a license by screening the parties and checking the country’s status — many transactions clear without one.
General vs. Specific Licenses
OFAC issues two kinds of licenses, and knowing which applies saves time and money.
| General license | Specific license | |
|---|---|---|
| What it is | A standing authorization in the regulations | Case-by-case written authorization |
| Who can use it | Anyone who meets its stated conditions | Only the applicant it is issued to |
| Application needed? | No — you self-qualify and document it | Yes — formal application to OFAC |
| Typical use | Common, lower-risk activities (e.g., certain Cuba travel, legal services, some humanitarian goods) | Anything not covered by a general license |
The first step is always to read the relevant sanctions program for an existing general license. If one fits your facts, you simply rely on it and keep records showing you met its conditions — no application required. Only when no general license covers your activity do you apply for a specific license.
OFAC’s authority to issue and condition these licenses comes from statutes including the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA), under which it administers each sanctions program.
How to Apply for a Specific License
Specific-license applications now run through OFAC’s online application portal. In 2025, OFAC modernized the system: as of February 2025 applicants can create an account (with identity verification through ID.me) to save drafts, track case status on a dashboard, and reuse contacts, and OFAC completed the transition to the online platform in August 2025. The core steps:
- Confirm the need — verify your transaction is actually prohibited and not already covered by a general license or exemption.
- Build the application — describe the parties, the transaction, the goods or services, the value, and the foreign-policy or humanitarian rationale. Detail and accuracy matter; vague applications stall.
- Submit through the portal — file the application and supporting documents via OFAC’s online system.
- Respond to follow-ups — OFAC routinely requests additional information; prompt, complete responses keep the case moving.
- Await the decision and comply with conditions — review can take weeks to many months depending on complexity, and an approved license almost always comes with conditions you must follow exactly.
Apply well ahead of any deadline. There is no guaranteed timeline, and rushing a thin application is the most common way to get delayed or denied.
What Makes an Application Succeed
OFAC weighs each request against U.S. national security and foreign-policy goals, so the strongest applications make the case that the transaction is consistent with — or at least not contrary to — those objectives. Common avoidable mistakes are incomplete information, missing supporting documents, ignoring program-specific instructions, and glossing over red flags rather than addressing them head-on. Humanitarian, medical, and certain personal or legal transactions tend to align with stated policy and fare better; purely commercial requests in sensitive programs face a steeper climb.
Frequently Asked Questions
What is an OFAC license?
It is authorization from OFAC to carry out a transaction that U.S. sanctions would otherwise prohibit. It comes in two forms: general licenses, which are standing authorizations anyone meeting the conditions can use, and specific licenses, which are issued case-by-case on application.
Do I need to apply for a general license?
No. A general license is built into the regulations — if your activity fits its conditions, you may proceed without applying, though you should document how you qualify. You only file an application when you need a specific license.
How long does an OFAC specific license take?
There is no fixed timeline. Review can range from a few weeks to many months depending on the program, the complexity of the request, and how complete the application is. Apply early and respond quickly to any OFAC follow-up.
What happens if my application is denied?
You can seek reconsideration by submitting additional information or argument addressing the basis for denial. Because a denial signals OFAC’s view of the transaction, it is worth getting counsel involved before refiling.
Getting a license wrong — or proceeding without one — carries serious civil and criminal exposure. Reidel Law Firm helps businesses determine whether a license is needed and prepare OFAC applications on flat-fee terms. Get an export compliance memo.
