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First, ask the exchange—in writing—whether it has formally blocked your assets under sanctions law, is investigating a possible name match, or has applied a different compliance restriction. Those situations have different rules and routes to resolution. The guidance below covers U.S. sanctions administered by the Office of Foreign Assets Control (OFAC); an exchange hold is not automatically an OFAC block, and the applicable law depends on the facts and jurisdictions involved.
Find out what kind of restriction the exchange imposed
A sanctions alert may prompt a review without confirming that your funds are blocked. An exchange may also restrict an account under a separate policy or legal obligation. Ask who imposed the restriction, what authority or policy the exchange relies on, and whether it considers the restriction a formal sanctions block.
| Situation | What it means | What to clarify |
|---|---|---|
| Possible match under review | The exchange is checking whether you or the assets match a sanctions concern; the alert alone does not establish that the funds are formally blocked. | Ask what information it needs, how to submit it securely, and how to contact the review team. |
| Formal OFAC block | The institution says it has blocked property under U.S. sanctions rules. The restrictions on dealing with the assets differ from an ordinary review. | Ask which authority or sanctions program applies, which assets are affected, and what process applies to a release or license request. |
| Other compliance or policy hold | The exchange restricts access for a reason other than a confirmed OFAC block, or has not identified an OFAC legal basis. | Ask for the specific policy or legal basis, the affected assets, the review process, and any appeal route. |
OFAC’s FAQ 51 advises people who believe their funds may have been blocked to confirm the status with the financial institution and ask for its sanctions-compliance staff. OFAC also says it does not itself hold blocked funds.
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- Get the explanation and next steps in writing. Request the case reference, the status and amount of affected assets, the basis for the restriction, the information needed for review, and the appropriate appeal or contact channel.
- Keep a complete record. Save the notice, dates, account details, transaction IDs, and all correspondence. OFAC’s FAQ 5 emphasizes complete and accurate records in sanctions-compliance decisions. Provide identity or business documents only through a secure channel identified by the exchange.
- If you believe the alert is a false match, respond with distinguishing evidence. Follow the exchange’s secure submission process and provide reliable information that addresses the suspected match. OFAC’s FAQ 1196 says the affected person should contact the organization that blocked the property; the institution, not the customer, handles a qualifying compliance-release request.
- If the block appears valid, ask which authorization route applies. OFAC says an institution needs authorization to release blocked property. A specific license may be relevant, but the right route depends on the sanctions program and circumstances. Consider a lawyer qualified in the relevant jurisdiction if the amount is material, the basis is disputed, or the matter is complicated.
Do not try to bypass a confirmed OFAC block by transferring assets through another account, wallet, or intermediary. OFAC generally prohibits transfers and other dealings in blocked property unless authorized.
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False match and valid block are different cases
| Case | Appropriate route | Why the distinction matters |
|---|---|---|
| Mistaken identity, typographical error, or other false positive | Send evidence to the organization that imposed the block and ask it to review the match. | Under OFAC FAQ 1196, the blocking organization may use a compliance-release process for qualifying false positives. |
| Property was correctly blocked, but circumstances later changed | Ask the institution or qualified counsel about the applicable OFAC authorization or specific-license process. | OFAC distinguishes a changed-circumstances case from a mistaken-identity release; it is not treated as a false positive simply because the situation has changed. |
A name appearing similar to a listed person does not, by itself, establish that an exchange has formally blocked your funds. The exchange’s stated legal basis and its review of the facts matter.
What an OFAC block means for crypto
OFAC describes blocked property as frozen, not seized. The owner generally retains title, but that does not permit withdrawing, transferring, or otherwise dealing in the property without authorization. For virtual currency, OFAC instructs U.S. persons that determine they hold currency that must be blocked to deny access and comply with holding and reporting requirements.
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The blocking party—not the customer—must report blocked property within 10 business days under the requirement summarized in OFAC FAQ 9 and FAQ 646. Blocked virtual currency must also be reported annually while it remains blocked, according to FAQ 646. These are reporting obligations for the party holding or blocking the assets, not a general deadline for a customer to appeal.
Check which jurisdiction and rules apply
The cited guidance is from U.S. OFAC and does not determine the rules for an unspecified non-U.S. jurisdiction, an exchange’s separate internal hold, or whether a particular person or asset is actually subject to a block. Your location, the exchange’s location, the transaction and the stated legal basis can all matter. If the exchange will not explain the basis, or the restriction has significant financial consequences, seek advice from a lawyer qualified in the relevant jurisdiction.
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