Where does the money end up?

General License FF, issued by the US Office of Foreign Assets Control, or OFAC, for Iraq’s International Development Bank for Investment and Finance, authorizes transactions ordinarily necessary to wind down dealings through 30 October. The decisive condition concerns the destination of money: payment to a blocked person must enter a blocked account. Closing a transaction therefore does not give the recipient freely usable funds. The clause separates ending a commercial relationship from giving the sanctioned party liquidity.[1]

The license excludes otherwise prohibited dealings with other blocked parties unless separately authorized. My reading is that exit requires a narrower transaction-level assessment than simply closing a relationship with one bank. In a payment chain with several parties, permission involving IDB does not automatically resolve restrictions elsewhere in the chain. An ordinary administrative accommodation for winding down business is a plausible interpretation too. Yet the blocked-account condition expressly limits that accommodation’s ability to release funds.[1]

A foreign customer’s deadline and a US bank’s permission

FAQ 1276 for Cuba’s state-owned Banco Internacional de Comercio, or BICSA, has a different structure. The US government sets out a posture of not targeting foreign persons, including foreign financial institutions, under this executive order for transactions ordinarily necessary to end dealings through 14 November. The same guidance says it does not authorize persons subject to US jurisdiction to transact with BICSA without separate permission, including participation in a foreign person’s wind-down.[1]

The consequence for a payment chain is that limited room afforded to a foreign customer does not travel automatically to an intermediary subject to US jurisdiction. A customer’s ability to exit before a deadline and the availability of an authorized channel are separate questions. Administrative continuity with existing Cuba sanctions is a strong alternative explanation for the difference; the guidance itself recalls that BICSA dealings have long been prohibited. There is no need to infer a new diplomatic bargaining intent. The existing prohibition continues to constrain the channel despite the wind-down statement.[1]

Exit involves more than a date

OFAC also warns foreign persons that returning assets to a sanctioned party, or transferring them elsewhere for that party’s potential use, can create sanctions risk. The blocked-account requirement for IDB and the distinction between foreign and US-jurisdiction persons for BICSA give concrete shape to how exit operates. Placing the deadlines beside each other does not create a single permitted payment route for every participant.[1]

These instruments do not establish which channels banks actually used or whether customers have ended their relationships. My strategic reading is narrower: US authorities accommodate exit while retaining control over where money remains and which intermediary can participate. A customer already wishing to leave for commercial reasons faces the same constraints. The practical test concerns both the relationship being closed and whether payment authority and asset destinations satisfy these conditions.[1]