OFAC Attorney: Yes, it is. As long as a blocked person or country also has an interest in your transaction, a U.S. person or bank will be required to block that transaction. OFAC broadly defines the term “interest” to include future, contingent, direct, indirect, tangible, or intangible interests in property. Even though multiple people can have an interest in the property, the existence of a blocked interest can cause the entire property to be blocked. In these instances it is important to hire an attorney who can seek license authorization from OFAC to unblock your interest in the property.
Additionally, the property will remain blocked until OFAC releases the property or the blocked interest is no longer considered blocked. The latter usually only happens when a designated person successfully petitions OFAC to be removed from the SDN list.