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Do not treat “sanctions waiver” as a general permission. To decide whether a Russian transaction may proceed, identify the exact U.S. sanctions prohibition, then match every fact of the proposed deal to a current OFAC exemption or license. The authorization must cover the activity, parties, ownership, goods or services, location, dates, currency and payment route, and every condition must be satisfied. A general license is self-executing only when its terms are met; a specific license authorizes only the named licensee and stated scope. If one required element is uncertain, pause the transaction and obtain sanctions counsel or seek an OFAC specific license.
What “waiver” means in U.S. sanctions practice
OFAC (the U.S. Department of the Treasury’s Office of Foreign Assets Control) generally uses the terms exemption, general license and specific license, rather than one universal “waiver.” The label used by a salesperson, counterparty or bank does not determine whether a transaction is lawful. The controlling document is the current statute, executive order, regulation, directive, exemption or license that applies to the exact conduct.
| Authorization | Who can use it | How scope is determined | Typical conditions |
|---|---|---|---|
| Statutory or regulatory exemption | Persons whose conduct falls within the exemption | The governing law and implementing regulations | Definitions, program-specific limits and exclusions; not stated generally and must be read in the applicable authority |
| General license | Any person meeting all terms of the published license | Activity, parties, geography, dates, property, payment method and exclusions written in the license | May include wind-down deadlines, reporting, recordkeeping, blocked-account treatment or payment instructions; not stated generally |
| Specific license | Only the licensee and other persons expressly covered | The individual authorization issued by OFAC | Expiration date, named parties, authorized transactions and any special conditions in that license; not stated generally |
OFAC describes general licenses as public and “self-executing”: a person who determines that a transaction meets every term does not need another OFAC approval. That does not make a general license a blanket clearance. A transaction outside one definition, after one deadline, involving one excluded party or using a prohibited payment channel is not covered.
Step 1: Define the transaction before looking for a license
Write a fact sheet before searching OFAC material. Vague descriptions such as “paying a Russian supplier” hide the facts that determine whether a restriction applies. Capture the following for the proposed transaction and any related transfers:
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- U.S. nexus: Identify every U.S. person, U.S.-organized entity, U.S. branch, U.S.-located person, U.S.-dollar clearing point and person acting from the United States. Also note non-U.S. participants whose conduct could cause a U.S. person to violate or evade a restriction.
- Parties and roles: Record the customer, supplier, carrier, insurer, agents, brokers, consultants, beneficial owners, directors where relevant, banks, correspondent banks and payment processors. Distinguish the contracting party from the party receiving funds or goods.
- Goods, services and technology: Describe the items precisely, including classification, end use, technical data, software, maintenance, financing, brokerage and any ancillary service. A license for one service does not automatically cover another.
- Origin, destination and routing: Record where goods are made, shipped, delivered, stored and ultimately used. Note transit countries and whether services are performed in Russia, for a Russian person or from a third country.
- Money flow: State currency, account owners, sending and receiving banks, correspondent and intermediary institutions, payment messages, netting or set-off arrangements, and whether a blocked account could be involved.
- Timing: Record contract date, performance dates, invoice dates, shipment dates, payment dates and any wind-down or expiration deadline in a potential authorization.
Preserve the fact sheet as the baseline for screening and approvals. If any fact changes, reassess the authorization rather than assuming the original conclusion carries over.
Step 2: Identify the exact prohibition
Start with the correct sanctions program
Use OFAC’s Russia-related sanctions materials and legal library to identify the governing program and authorities. Depending on the facts, the issue may arise under the Ukraine-/Russia-related sanctions regulations, Russian Harmful Foreign Activities regulations, an executive order, a directive, sectoral restrictions, correspondent-account rules or a combination. The same commercial purpose can be treated differently under different programs.
List each prohibition that could apply, not just the most obvious one. For example, a sale of goods may involve a property-blocking prohibition, a sectoral debt or equity directive, an export-control issue outside OFAC, and a separate restriction on the bank that processes the payment. An authorization addressing one layer does not silently remove the others.
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Determine whether the proposed conduct would involve property or an interest in property of a blocked person, a prohibited service, dealings in restricted debt or equity, a sovereign transaction, or use of a prohibited correspondent or payable-through account. Record the legal citation for every prohibition that must be overcome. This makes it possible to test whether the candidate authorization actually reaches the conduct.
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Check for anti-evasion and facilitation concerns
Changing the invoice currency, inserting a third-country intermediary or renaming a service does not remove a prohibition if the underlying transaction remains restricted. Review who arranged, approved, financed and routed the activity. A structure that appears different on paper may still involve a blocked person, a prohibited benefit or an attempt to evade sanctions.
Step 3: Find and read the complete authorization
Search for the current text of the exemption or general license that appears to address the identified prohibition. Read the instrument itself, including definitions, annexes, exclusions, notes, reporting clauses, recordkeeping requirements, payment provisions and expiration or wind-down dates. Do not rely on a headline, a prior version, a law-firm summary or a counterparty’s statement that a “waiver” exists.
- Authorized activity: Confirm that the text covers the specific sale, service, investment, transfer, withdrawal, shipment or other act you will perform.
- Eligible persons: Check whether the authorization is available to all persons, only U.S. persons, specified entities, financial institutions, nongovernmental organizations or named parties.
- Property and sector: Match the goods, technology, debt, equity, industry and end use to the license language and any annex.
- Geography: Check Russia, occupied regions, third countries, territorial waters, transit and the location where a service is performed.
- Time: Verify effective, expiration and wind-down dates. A payment made after a deadline may not be covered even if the contract was signed earlier.
- Exclusions: Read every excluded person, bank, product, sector, activity and transaction type. Exclusions often control the result.
- Conditions: Identify required certifications, reports, notices, record retention, blocked-account handling, payment routing and other prerequisites.
Make an element-by-element comparison between the fact sheet and the authorization. Mark each element “satisfied,” “not satisfied” or “uncertain,” and retain the text version and retrieval date. “Uncertain” is not approval.
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Screen names, aliases and roles
Screen all parties and relevant intermediaries against current OFAC lists, using legal names, trading names, transliterations, aliases and known account details. Screen the beneficial owners of entities, not just the name printed on the invoice. Repeat screening shortly before execution and whenever a party, bank, ownership structure or payment instruction changes.
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Apply ownership aggregation
Under OFAC’s 50 Percent Rule, an entity is generally blocked when one or more blocked persons own, directly or indirectly, 50 percent or more of it in the aggregate. Ownership is aggregated across blocked owners; separate holdings that total 50 percent can therefore block the entity. An ownership percentage below 50 percent is not automatically blocked by that rule, but the entity may still be designated, controlled for another reason, or involved in a separately prohibited transaction.
Obtain reliable ownership evidence, map indirect ownership through each intermediary entity and record the calculation. If ownership is opaque, recently changed or disputed, escalate instead of treating the absence of a matching name as clearance.
Check whether the authorization changes the screening result
A license may authorize dealings with a blocked person only within a tightly defined scope, or it may exclude particular blocked persons. Do not infer that an authorization covering a type of activity permits all transactions with every Russian counterparty. Compare each screened person and entity to the authorization’s eligible-party and exclusion language.
Step 5: Review Russia-specific banking restrictions separately
Payment processing can be prohibited even when the underlying sale or service is authorized. Review directives affecting debt, equity, sovereign transactions, correspondent or payable-through accounts, and foreign financial institutions. Also check whether a bank is blocked or subject to CAPTA restrictions. A license for the commercial activity does not automatically authorize a bank to maintain or use a restricted account.
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| Payment question | What to verify | Why it matters |
|---|---|---|
| Who sends and receives funds? | Legal account holders, beneficial owners and all banks in the chain | A blocked person or restricted institution can invalidate the route even if the contract is licensed. |
| Is a correspondent or payable-through account involved? | Account type, bank location and applicable directive or CAPTA prohibition | Correspondent-account restrictions operate separately from the underlying trade authorization. |
| Can the transfer pass directly? | Whether the license requires an indirect route through a non-sanctioned, non-U.S. financial institution | OFAC funds-transfer guidance says certain authorized transfers must use an indirect route of this kind. |
| What happens if funds are blocked? | Required blocked-account treatment, notice and reporting | Moving, netting or returning blocked funds without authorization can create a new violation. |
OFAC FAQ 1182, updated June 11, 2026, addresses current treatment of authorized Russia-related activities for foreign financial institutions. Because bank practices and sanctions lists change, check the current FAQ and applicable directives immediately before execution rather than relying on an older payment precedent.
Step 6: Validate the route with every bank
- Give the sending, receiving and intermediary banks a concise transaction package: parties, ownership chart, goods or services, destinations, dates, currency, account details, screening results and the exact license or exemption citation.
- Ask each bank to confirm whether it will process the proposed route and whether it requires a different correspondent, payment message, certification or supporting document.
- Verify that no intermediary is blocked or subject to CAPTA treatment and that the proposed route does not use a prohibited correspondent or payable-through account.
- Record each bank’s decision, the reviewer, date, conditions and any requested changes. Re-test the route after any change to a bank, account, currency, invoice or beneficiary.
A bank’s refusal does not by itself prove that OFAC prohibits the transaction; banks may apply stricter risk policies. It is nevertheless a practical stop signal. Escalate the legal analysis, seek an alternative route only if it is independently lawful, and never pressure a bank to ignore its compliance decision.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Step 7: Build a defensible decision file
Your file should allow an independent reviewer to reproduce the decision months later. Keep:
- The transaction fact sheet and all later amendments.
- The exact authorization text, version and retrieval date.
- An element-by-element comparison showing how each term is met.
- List-screening results, search parameters, aliases and screening dates.
- Ownership evidence, calculations under the 50 Percent Rule and unresolved ownership questions.
- Contract, invoice, shipping, end-use, technical and payment documents.
- Bank correspondence, routing approvals, certifications and any required reports.
- Decision-maker approval, escalation notes and legal advice where obtained.
- Blocked-account instructions and evidence of reporting if funds or property must be blocked.
OFAC’s 2019 compliance framework identifies five essential components: management commitment, risk assessment, internal controls, testing and auditing, and training. Apply those components to Russia transactions in proportion to their risk. A single checklist is not a substitute for ownership controls, payment testing and trained reviewers.
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Decision rule: when to proceed, pause or seek a specific license
Proceed only when all five tests are positive:
- The applicable prohibition and sanctions program are identified.
- A current exemption or license covers the exact activity, parties, property, geography and dates.
- Every condition, exclusion, reporting duty and payment requirement is satisfied.
- All parties and owners clear screening, including the 50 Percent Rule analysis.
- The proposed payment path is permissible and accepted by the participating banks.
Pause when any answer is “uncertain,” when a license has expired or changed, when ownership cannot be verified, when a bank or intermediary is restricted, or when the transaction facts differ from the authorization’s scope. Obtain sanctions counsel or apply for an OFAC specific license when the activity is not clearly covered. Do not convert an unresolved question into a commercial assumption.
Worked examples
A licensed service but a restricted bank
A U.S. company finds a general license that appears to permit a particular service for a Russian customer. The customer’s operating company is not listed, but its payment bank is subject to a correspondent-account restriction. The company must analyze the bank restriction separately, confirm whether the license prescribes an indirect route through a non-sanctioned, non-U.S. institution, and obtain approval from every bank in the final chain. The service authorization alone is insufficient.
Ownership below 50 percent but a listed individual
A Russian entity is 40 percent owned by a blocked person and 60 percent by an unblocked investor. The 50 Percent Rule does not automatically block the entity on those figures alone. Screening must continue: the entity could be independently designated, controlled by a blocked person, or involved in a prohibited activity. Document the ownership calculation and the separate control and activity analysis.
Payment after a wind-down deadline
A contract was signed while a general license was active, but shipment and payment occur after its wind-down period. The relevant question is whether the license expressly covers performance or payment after that date. If it does not, the original contract date does not preserve authorization. Stop and obtain a current legal basis before moving funds or goods.
Common mistakes and how to correct them
- Relying on the word “waiver”: Replace the label with a citation to the exact exemption, general license or specific license and test its terms.
- Reading only the headline: Review definitions, annexes, exclusions, deadlines, reporting and payment clauses in the complete current text.
- Screening only the contracting party: Screen owners, agents, carriers, banks, correspondents, processors and other participants.
- Stopping at name screening: Perform ownership aggregation and investigate control, sector and transaction restrictions.
- Assuming a licensed sale makes payment lawful: Analyze correspondent, payable-through, CAPTA and foreign-financial-institution restrictions separately.
- Using an old approval: Re-screen and re-check the authorization whenever lists, directives, ownership, banks, dates or payment instructions change.
- Allowing a bank refusal to become the legal analysis: Treat the refusal as a stop signal, document the reason and obtain qualified escalation.
- Failing to preserve evidence: Keep the license version, retrieval date, calculations, searches, approvals and routing records in one decision file.
Execution checklist
- All parties, owners, banks and intermediaries are identified.
- Goods, services, technology, end use, origin, destination, currency and dates are documented.
- Every potentially applicable Russia-related prohibition is cited.
- The current exemption or license text has been read in full.
- Each authorization condition and exclusion is marked satisfied or escalated.
- OFAC list screening and 50 Percent Rule calculations are complete.
- Correspondent, payable-through, CAPTA and foreign-financial-institution issues are resolved.
- Each bank has reviewed the actual payment path.
- Reporting, recordkeeping and blocked-account procedures are assigned.
- Management approval and a reassessment date are recorded.
Keep the conclusion current
Russia-related license numbers, expiration dates, designations, directives and bank-routing practices are volatile. Re-check OFAC immediately before execution and whenever transaction facts change. A conclusion is defensible only for the facts and authorization version that were actually reviewed; it is not a permanent clearance for future payments.
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