INTERNATIONAL TRADE LAW

OFAC Sanctions Licensing: General vs. Specific

An OFAC license is permission from the U.S. Treasury to do a transaction that sanctions would otherwise prohibit. The Office of Foreign Assets Control (OFAC) administers U.S. economic and trade sanctions, and when a deal touches a sanctioned country, person, or activity, a license is often the only lawful way to proceed. Understanding the two kinds of license — general and specific — is the first practical step.

For related reading, see our overviews of OFAC sanctions compliance and how to apply for OFAC licenses.

General license vs. specific license

This is the distinction that matters most:

General licenseSpecific license
What it isA standing authorization for a whole category of transactionsA written authorization for one applicant’s particular transaction
Do you apply?No — it is already published in the regulationsYes — you apply to OFAC and wait for a decision
ConditionsYou must meet every stated condition exactlyOFAC sets the terms and any limits in your license
Best forRoutine, pre-approved activityOne-off or unusual deals not covered by a general license

A general license is self-executing. If your transaction fits squarely within a published general license and meets all its conditions, you do not need to ask OFAC — you simply keep records showing you qualified. A specific license is what you request when no general license covers you; you file an application through OFAC’s licensing portal and cannot proceed until OFAC grants it.

The practical workflow is: figure out whether the transaction is even prohibited, check whether a general license already authorizes it, and only then apply for a specific license.

Who and what OFAC reaches

OFAC sanctions fall into two broad shapes:

  • Comprehensive programs target entire jurisdictions — historically Cuba, Iran, North Korea, Syria, and the Crimea and other occupied regions of Ukraine — where m