The bank is still holding the funds.

Even after OFAC approves an unblocking, there can be delays in actually receiving funds because banks conduct their own review process. OFAC’s authorization doesn’t obligate a bank to process the transaction – banks can still decline based on their own risk appetite. First, ensure you have written documentation of OFAC’s decision to release the funds. Provide this to your bank along with any supporting materials you submitted to OFAC. Banks typically conduct their own sanctions review and compliance check before releasing blocked funds. They may require additional documentation from you – proof of identity, transaction details, source of funds, etc. This secondary review can take weeks. If the bank continues to hold funds despite OFAC authorization, request a clear explanation of what additional steps are needed. Sometimes banks have internal policies stricter than OFAC requirements. I dealt with this frustrating situation and found practical guidance at https://ofacblockedfundslawyers.com/ about navigating bank holdups. Consider whether the bank is willing to continue the relationship or if you need to find a new banking partner. Some banks, after a blocking incident, prefer to close the account even if funds are released. Be patient but persistent – maintain regular contact with the bank and document all communications. If unreasonable delays persist, you might escalate within the bank or consider regulatory complaints, though this should be a last resort.