Skip to content
Distributed Risk
Distributed Risk
Guides

OFAC general licenses: what to check before relying on one

Quick answer, Oct 28, 2026As of 28 October 2026, before relying on an OFAC general license, check five things on the official record: the program it sits under, who and what it covers, its expiry or wind-down date, any conditions or reporting terms, and whether OFAC has amended or replaced it. Read the license text, then the related FAQs.

The five checks

  1. Program and authority. Which sanctions program, and which executive order or regulation, the license sits under.
  2. Scope. Which parties, activities and goods or services it covers, and what it excludes.
  3. Dates. When it expires, and whether a wind-down period applies.
  4. Conditions. Reporting, recordkeeping and any limit on who you may deal with.
  5. Changes. Whether OFAC has issued an amended or replacement license, or an FAQ that changes how to read it.

Read the license text itself, then the related FAQs. list_ofac_actions on the Distributed Risk MCP server lists OFAC's recent actions, general licenses and FAQs by date.

Screening is separate

A screening match is a lead to check against the official entry. No match is not a clearance. Use search_screening_lists for names, aliases and identifiers, then confirm on the official list.

Examples on the desk

Our desk notes take one official action each and say what it means for the reader it is written for, with what would change the call. Recent examples: Venezuela General License 60A and amended FAQ 1263 (16 October 2026), Russia General License 135 for Russian-origin diesel fuel (9 October 2026), Iran GL EE and amended Russia GL 13S (8 October 2026) and two new general licenses with five PAIPA entities (19 October 2026).

When you need people on the ground

If a decision needs an investigation, protection or insurance in a particular country, brief an advisor: we arrange it with a partner firm that works there.

Questions

Can a company in a sanctioned country rely on a general license? It depends on the license's scope and your own obligations. Take advice from counsel; this page is a checklist, not a determination.

Brief an advisor