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 transaction fact to a current exemption or OFAC general or specific license. The authorization must cover the parties, ownership, goods or services, location, dates, currency, payment route and any reporting or recordkeeping conditions. A general license is self-executing only when all of its terms are satisfied; a specific license authorizes only the named licensee and stated scope.
If one required element is uncertain, pause the transaction, document the issue and obtain sanctions counsel or seek an OFAC specific license. A bank’s willingness to process a payment is not a substitute for the legal analysis.
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What a U.S. sanctions “waiver” actually means
“Waiver” is often used loosely in commercial discussions. U.S. sanctions law normally works through several different mechanisms, each with a different scope:
| Authorization | Who may rely on it | How scope is determined | Practical implication |
|---|---|---|---|
| General license | Any person whose transaction meets the published terms | The complete current license, including definitions, annexes, exclusions, deadlines and conditions | Public and self-executing; no separate OFAC approval is needed when every condition is met |
| Specific license | Only the person or organization named in the license | The license document’s named parties, activity, property, period and other limits | Case-specific; it cannot be transferred to an unlisted party or broader transaction |
| Program exception or exemption | Persons and activities within the relevant statute or sanctions program | The exact regulation, executive order, directive or statutory text | Exceptions vary by program and may not address banking, ownership or another separate prohibition |
The Office of Foreign Assets Control (OFAC) describes general licenses as public and “self-executing”: a person who determines that a transaction meets the license terms does not need further OFAC authorization. That does not make a general license a blanket waiver. Missing one condition, using an expired version or involving an excluded person can put the transaction outside the authorization.
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OFAC also warns that exceptions differ in type and scope across sanctions programs. A permission under one Russia-related authority does not automatically override a prohibition imposed by another directive, regulation or statute.
Start with a complete transaction record
Before searching for a license, write down the transaction as it will actually occur. Vague descriptions such as “payment for Russian goods” are not enough for a defensible decision.
Capture the U.S. nexus
- Identify every U.S. person involved, including the buyer, seller, owner, employee, agent, bank, payment processor and service provider.
- Record any U.S.-dollar clearing, U.S. correspondent bank, U.S.-origin goods or technology, or activity taking place in the United States.
- Note whether a non-U.S. company is acting for, owned by or controlled by a U.S. person.
Identify all participants and control relationships
- Legal name, trade name, aliases, registration number and country for each counterparty.
- Beneficial owners, parent companies, subsidiaries, directors and authorized signatories.
- Every bank, correspondent, payable-through account, broker, freight forwarder, insurer and other intermediary.
Describe what moves and where
- Exact goods, services, software, technology or financing arrangement, with classification or part numbers where relevant.
- Origin, destination, transit countries, end user and end use.
- Currency, value, invoice dates, shipment dates, contract dates and proposed settlement dates.
- The precise funds flow: origin account, intermediary institutions, beneficiary account and any conversion or netting step.
Keep this inventory with the compliance file. If any fact changes—such as a new bank, route, owner, product, date or consignee—re-run the analysis rather than assuming the original conclusion still applies.
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Read the rule that could prohibit the transaction, not just a license that appears commercially convenient. OFAC’s Russia-related sanctions materials point users to the Russia sanctions program page, the Ukraine-/Russia-related and Russian Harmful Foreign Activities regulations, relevant executive orders and directives, and rules governing sectors and correspondent accounts.
Questions that locate the relevant rule
- Is property or an interest in property blocked because a participant is listed?
- Does a directive restrict debt, equity, sovereign transactions, new investment or another sectoral activity?
- Does the transaction involve a prohibited correspondent or payable-through account?
- Is a foreign financial institution subject to a separate restriction even though the underlying trade is authorized?
- Are the goods, services, technology, destination or end use subject to a Russia-specific prohibition?
- Does a wind-down, reporting or expiration date apply?
Write the prohibition and its legal authority in the file. Without that first step, it is easy to rely on a license that addresses one activity while leaving a second, independent prohibition untouched.
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Read the complete current authorization
Use the current text published by OFAC, not a summary, old transaction template or a counterparty’s description of a “waiver.” Check the version and retrieval date, then read every operative provision.
What to check in a general license
- Authorized activity: Confirm that the license covers the actual goods, services, financing, wind-down or other activity, rather than a similar commercial purpose.
- Eligible persons: Check whether U.S. persons, non-U.S. persons, blocked persons, foreign financial institutions or particular sectors are included or excluded.
- Property and counterparties: Look for named entities, blocked-property clauses, ownership conditions and restrictions on dealing with listed persons.
- Geography and routing: Verify origin, destination, transit, place of performance and any required non-sanctioned intermediary.
- Dates: Compare contract, shipment, service, payment and wind-down dates with the license’s effective and expiration dates.
- Conditions: Identify certification, reporting, notice, recordkeeping, account-blocking or other procedural requirements.
- Exclusions and annexes: Review every excluded product, sector, person, bank, transaction type and referenced annex.
- Payment language: Determine whether the license permits the proposed funds flow or only the underlying activity.
Save a copy of the text or a stable internal record showing the version you relied on. Sanctions lists, license numbers, expiration dates and banking practices can change quickly; re-check immediately before execution.
How a specific license differs
A specific license is not a public permission that any similarly situated company can use. It is case-specific and limited to the named licensee, named or described parties, authorized property or activity, period and conditions. Verify that your entity is the licensee, that the transaction falls within the stated scope and that no amendment or expiration has narrowed it. Do not share or “extend” the license to an affiliate, supplier or bank that is not covered.
Screen every party and apply the 50 Percent Rule
Screen all names and aliases against current OFAC lists before signing, shipping or paying. Screening only the Russian seller is inadequate: banks, owners, intermediaries, consignees, service providers and beneficial owners can independently create a sanctions problem.
Ownership analysis
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 in the aggregate. Ownership can be combined across multiple blocked owners. An entity below 50 percent is not automatically blocked by that rule, but it may still be prohibited because it is listed, controlled, involved in a restricted activity or connected to another rule.
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Obtain current ownership evidence—such as corporate records, reliable registry information, certifications and an ownership chart—and record how indirect interests were calculated. Re-check after ownership changes, mergers, new financing or credible adverse information. A name-screening result that is “clear” does not eliminate the need to analyze ownership.
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Authorization of a sale, service or other underlying activity does not necessarily authorize the bank route. Review directives affecting debt, equity, sovereign transactions, correspondent or payable-through accounts and foreign financial institutions. Also check whether an intermediary is blocked or subject to CAPTA-related restrictions.
Map the funds flow
- List the payer’s account bank and every correspondent or intermediary.
- Identify the beneficiary’s bank, its ownership and any parent or affiliate used in clearing.
- Show the currency conversion, netting, escrow, settlement or reimbursement steps.
- Match each institution and step to the license’s payment language and to separate correspondent-account rules.
- Retain written payment instructions and evidence that the route used at settlement is the route analyzed.
OFAC funds-transfer guidance indicates that certain authorized Russia-related transfers must be routed indirectly through a non-sanctioned, non-U.S. financial institution. The exact requirement depends on the applicable authority, so do not assume that a direct U.S. transfer is permitted merely because the commercial activity is licensed.
OFAC FAQ 1182, updated June 11, 2026, addresses current treatment of authorized Russia-related activities for foreign financial institutions. Use the current FAQ and underlying legal authority when assessing a foreign bank; do not rely on an older bank memo or a generic statement that “payments are allowed.”
Obtain the banks’ compliance decisions—but do not outsource the legal conclusion
Give each involved bank the license citation, transaction description, parties, ownership information and proposed funds flow. Ask whether its compliance team will process the specific payment and whether it requires certifications, alternative routing or additional documents.
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A bank refusal does not by itself prove that OFAC prohibits the transaction. Banks may apply policies stricter than the law, lack correspondent capacity or avoid a risk they cannot operationally manage. Treat a refusal as a practical stop signal: pause, escalate internally, determine whether the route can lawfully change and document the decision. Never conceal a party, split a payment or alter invoice descriptions to obtain processing.
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A conclusion should be reproducible by another reviewer after the transaction. Keep the following records together:
- Transaction inventory, contracts, invoices, shipping and end-use documents.
- Applicable regulation, directive, executive order, exemption and general-license text, with license number, version and retrieval date.
- Element-by-element matrix showing how each license condition is met or why it is not applicable.
- List-screening results, aliases, ownership documents, calculations under the 50 Percent Rule and escalation notes.
- Bank names, account details, routing diagram, bank questions and written processing decisions.
- Required reports, certifications, blocked-account treatment and proof of submission.
- Approvals, training records and evidence of review when facts changed.
OFAC’s 2019 Framework identifies five essential compliance components: management commitment, risk assessment, internal controls, testing and auditing, and training. Apply those components proportionately to the transaction’s risk. Regular screening and reassessment matter because lists, directives, licenses and banking practices change.
A practical decision rule
Proceed only when all five gates below are satisfied:
- Prohibition identified: You have named the exact Russia-related prohibition, regulation, directive or other authority that could apply.
- Authorization matched: A current exemption or license covers the exact activity, parties, property, geography and dates.
- Conditions satisfied: Every exclusion, payment condition, reporting duty, recordkeeping requirement and deadline has been met.
- Screening clear: Parties and owners are not blocked or otherwise prohibited, and the 50 Percent Rule analysis is documented.
- Payment route permissible: Every bank and intermediary is acceptable under both the authorization and separate correspondent, payable-through or CAPTA restrictions.
If any gate fails or remains uncertain, do not proceed on the strength of a broad “waiver” reference. Pause the transaction, obtain specialized sanctions advice and consider whether an OFAC specific-license application is required.
Worked examples
Licensed goods, but a blocked owner appears
A general license may authorize a category of goods, yet the Russian buyer is 52 percent owned in aggregate by blocked persons. The ownership rule independently blocks the entity. The goods description cannot cure that problem; stop unless a separate, applicable authorization covers the blocked-property issue.
Underlying service authorized, bank route not authorized
A U.S. company determines that a service falls within a current general license. The proposed payment would pass through a bank subject to a correspondent-account restriction. The service analysis does not automatically authorize that route. Re-map the funds flow, obtain bank guidance and use only a route permitted by the applicable authority.
Specific license held by an affiliate
An affiliate receives a specific license for a defined wind-down. The parent company cannot assume it may use the license for its own contract or extend it to a different supplier. Confirm the named licensee, parties, property, dates and conditions; seek separate authorization if the transaction falls outside them.
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Facts change after approval
The counterparty changes its bank and adds a new intermediary after compliance approval. The original file no longer proves that the payment path is permissible. Re-screen the new institutions, compare the new route with the license and obtain a fresh bank decision before payment.
Common mistakes that invalidate a “waiver” analysis
- Calling a commercial exception a waiver without citing the controlling authority.
- Reading only the license headline and ignoring definitions, annexes or exclusions.
- Using an expired license or an old copy without checking the current text.
- Screening names but not indirect ownership or aliases.
- Assuming a below-50-percent owner is automatically safe from every other prohibition.
- Analyzing the seller and buyer but not banks, correspondents, brokers and freight providers.
- Assuming a licensed underlying activity makes every payment route lawful.
- Relying on a bank’s acceptance as proof that OFAC permits the transaction.
- Failing to re-check when dates, products, owners, banks or routing change.
- Keeping no evidence of the rule, license version, screening, approvals or required reports.
When to escalate
Escalate to sanctions counsel or OFAC when the authorization’s wording is ambiguous, a party may be owned or controlled by a blocked person, a bank is subject to a separate restriction, the transaction involves sovereign or sectoral directives, the payment route cannot be documented, or a required condition cannot be met. A conservative pause is preferable to relying on an informal waiver description that does not match the law.
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