We have started submitting applications to the US OFAC for obtaining individual licenses

In February 2024, the United States imposed blocking sanctions against SPB Bank, which serves as the settlement depository for SPB Exchange. These measures were a logical continuation of the U.S. sanctions policy initiated in November 2023, when SPB Exchange itself was added to the U.S. sanctions list. At the time the sanctions were imposed, SPB Bank was a subsidiary of SPB Exchange, which effectively meant that the sanctions regime was extended to the exchange as well.

As a result, all assets held by Russian private investors through SPB Bank became blocked under the sanctions imposed by OFAC (Office of Foreign Assets Control).

Frozen Assets Remain Inaccessible for Investors

Since the imposition of sanctions against SPB Exchange, a significant amount of time has passed. Despite SPB Bank’s attempts to resolve the issue with OFAC, the assets of investors remain frozen. This has created serious difficulties for asset holders, who have lost access to their funds. The uncertainty regarding the duration of the sanctions and the possibility of unblocking the assets continues to raise serious concerns among investors.

Why You Should Not Wait for Automatic Unblocking

Under current conditions, waiting for automatic unblocking of assets is not a realistic scenario. According to OFAC rules, assets may be unblocked only in exceptional circumstances—through the issuance of an individual OFAC license. This license allows a specific individual or entity to engage in transactions that would otherwise be prohibited under the current U.S. sanctions regime.

How the OFAC Individual License Process Works

The process of obtaining an individual OFAC license involves several key stages:

1. Preparing the Application:

A complete set of documents must be collected, confirming ownership of the assets and providing a justification for why the assets should be unblocked.

2. Submitting the Application to OFAC:

The prepared application is submitted to OFAC, including all supporting documents and a detailed legal rationale.

3. Application Review:

OFAC reviews the materials. The process can take a significant amount of time, depending on the complexity of the case and the current workload of the regulator.

4. Decision:

After reviewing the application, OFAC either issues an individual license or denies the request.

How We Help Clients Unblock Assets Through OFAC

Understanding that obtaining an individual OFAC license is currently the only effective legal mechanism for unblocking assets, we have begun actively filing such applications on behalf of our clients. This process requires a high level of legal precision and detailed document preparation, as the outcome heavily depends on the quality and completeness of the submitted materials.

We work closely with each client to ensure that their case is clearly, accurately, and persuasively presented to OFAC.

Prospects for Unblocking Assets Held Through SPB Bank

The situation with frozen assets of Russian investors held via SPB Bank remains legally complex and politically sensitive. However, the existence of an official OFAC procedure for issuing individual licenses provides real hope for the unblocking of assets—provided that the request is properly drafted and substantiated.

The law firm DTK Partners offers comprehensive legal support to clients affected by U.S. sanctions and manages the entire process of communication with OFAC—from assessing the chances of success to preparing a complete document package and submitting the application.

📩 Contact us today to schedule a consultation and begin the process of applying for an individual OFAC license — a key step toward regaining access to your blocked assets under the current U.S. sanctions regime.