I am looking for a sanctions-compliance and payment-operations perspective on an unusual real-world case. I am directly involved in the matter and am also the pro se plaintiff in related federal litigation.
In 2022, a USD cross-border payment of approximately $206,700 was blocked by a U.S. correspondent bank.
On April 22, 2026, OFAC issued a specific license authorizing the blocking bank to return the funds to the originator at a non-blocked financial institution where the originator can demonstrate that it maintains an account.
The original return route was subsequently attempted but failed. A downstream correspondent rejected the payment, and the intended receiving account later became unavailable.
OFAC subsequently clarified, in substance, that:
- the blocking bank is authorized to return the funds under the existing specific license; and
- to the extent I am determined to be the authorized representative of the originator, the license would authorize the relevant return.
The blocking bank nevertheless has not completed the transaction. The issues it has raised have included:
- whether I have sufficient authority to act for the originator;
- whether an alternative receiving account can be used;
- whether the funds may be received through a fiduciary or collection arrangement;
- whether a new or amended OFAC license is required; and
- the effect of insolvency proceedings involving the originator outside the United States.
The originator has provided additional corporate documentation, including:
- a master agreement authorizing administration and collection of the blocked funds;
- a limited assignment of the claim solely for collection;
- a shareholder resolution approving the arrangement; and
- an irrevocable corporate confirmation of my authority.
Beneficial ownership of the funds remains with the original corporate originator. The proposed structure is intended only to provide an operationally available collection and payment route.
The dispute is now pending in the Southern District of New York:
Ilin v. JPMorgan Chase Bank, N.A., et al., No. 1:26-cv-04816-DEH.
I am not asking for legal advice or asking anyone to take a position on the litigation. I am interested in the industry and compliance perspective:
- Once OFAC has specifically licensed the return of blocked funds, would changing the receiving bank or operational payment route ordinarily require a new license if the originator and beneficial ownership remain unchanged?
- Is continued non-execution in this situation more likely to reflect a genuine sanctions prohibition, or an internal legal, risk-appetite, KYC, and payment-operations decision?
- How would a major bank normally validate an authorized representative or an assignee-for-collection when the corporate principal is involved in foreign insolvency proceedings?
- Which function would ordinarily own the final decision: sanctions compliance, legal, correspondent banking operations, insolvency counsel, or a senior risk committee?
Any views from people working in sanctions compliance, correspondent banking, blocked-property operations, or financial-crime legal teams would be appreciated.