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First, ask the exchange to confirm in writing whether your account is under review, subject to an actual sanctions block, or restricted for another reason. The next steps differ: challenge a possible mistaken match with evidence, but do not try to move assets subject to a confirmed U.S. sanctions block. The guidance below concerns U.S. Office of Foreign Assets Control (OFAC) rules; it does not determine the law that applies to an exchange or customer elsewhere.
Find out what kind of restriction the exchange imposed
A sanctions alert is not, by itself, proof that OFAC has blocked your funds. An exchange may be checking a possible match, applying a separate compliance or policy hold, or reporting an actual block. OFAC does not itself hold blocked funds. In FAQ 51, it advises people who believe their funds were blocked under its sanctions to confirm the situation with the financial institution and ask for its sanctions-compliance staff.
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| Situation | What it means | Your next step |
|---|---|---|
| Possible match under review | The exchange has not confirmed that it formally blocked the assets. The alert may require further identity or transaction checks. | Ask what information it needs, how to submit it securely, and how to follow up on the review. |
| Confirmed sanctions block | The institution says it blocked specified property under a sanctions authority. For a U.S. OFAC block, the restrictions described below apply. | Ask which authority or sanctions program applies and whether your case is a possible false match or a valid block. |
| Another exchange restriction | The hold may be based on an exchange policy or another legal requirement rather than an OFAC block. | Request the specific basis, the affected assets, and the exchange’s review or appeal process. OFAC guidance does not settle the rules for this separate hold. |
What to do first
- Request a written explanation. Ask whether the restriction is a formal sanctions block, a potential match being reviewed, or another compliance restriction. Request the stated authority or policy, which assets are affected and their status, what information the exchange needs, a case reference, and the correct contact or appeal route.
- Keep a clear record. Save the notice, account details, transaction identifiers, and all correspondence. Keep copies of documents you submit and note when and how you sent them. Send identity or business documents only through a secure channel identified by the exchange. OFAC’s sanctions-compliance framework emphasizes complete and accurate records supporting match determinations; preserving your own communications helps you track the case.
- Use the exchange’s process to challenge a possible false match. If you believe the alert is mistaken, provide reliable information that distinguishes you or your business from the person or entity named. Ask the exchange what evidence is useful and follow its secure submission instructions. OFAC FAQ 1196 directs an affected person to contact the organization that blocked the property; that organization, not the customer, handles any qualifying compliance-release request.
- For a valid block, ask about authorization. Ask the exchange what authorization or license route applies to your circumstances. OFAC says an institution needs authorization to release blocked property. A specific license may be relevant, but the applicable route depends on the sanctions program and facts. Consider a lawyer qualified in the relevant jurisdiction if the amount is material, the block is disputed, or the situation is complicated.
What an OFAC block means for your crypto
OFAC describes blocked property as frozen, not seized: title remains with the blocked person, but the property generally may not be transferred, withdrawn, or otherwise dealt in without authorization. Continuing to own the assets does not itself give you permission to move them. Do not try another account, intermediary, wallet, or route to get around a confirmed block.
For virtual currency, OFAC instructs U.S. persons who determine that they hold currency that must be blocked to deny access and comply with the applicable holding and reporting requirements. Under OFAC’s guidance, the party holding or blocking the property must report blocked property within 10 business days; blocked virtual currency also requires annual reporting for as long as it remains blocked. These are reporting duties of the blocking party, not a general deadline for a customer to appeal or receive a decision.
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False match or valid block: why the distinction matters
A false positive—such as mistaken identity or a typographical error—is different from property that was correctly blocked but might later qualify for release because circumstances changed. For a suspected false match, provide distinguishing evidence to the organization that imposed the block and ask it to assess the case. For a valid OFAC block, ask about the applicable authorization process; changed circumstances do not turn a valid block into a mistaken-identity case. OFAC FAQ 1196 describes this distinction and the organization’s role in a qualifying compliance release.
A name match alone does not establish that the exchange has formally blocked your funds. The exchange’s explanation, the applicable authority, your circumstances, and the assets’ status matter. OFAC’s FAQs 9, 51, 646–647, 1196, and 5 explain its U.S. framework, but they do not determine the law governing a particular non-U.S. customer or an exchange’s separate internal hold.
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