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The Finance Base
international payments

What to Do When an International Payment Is Delayed or Blocked by Sanctions

A late international transfer is not automatically frozen. Find out what status to confirm with your bank, what records to keep, and how US and UK sanctions processes differ.

By TheFinanceBase Team 4 min read
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First find out whether the transfer is still pending, has been rejected and returned, or has been formally blocked or frozen. Contact your sending bank through a verified channel and request a trace, the institution currently handling the payment, and the reason it cannot proceed. A late payment alone does not establish that sanctions are involved.

Find out what happened to the payment

Ask the sending institution to trace the transfer and tell you its current status. Banks may not be able to disclose every detail, but ask what they can confirm and record the case or reference number.

  1. Contact the bank using the phone number or secure messaging in its official app or on its website.
  2. Ask: Is the transfer pending, rejected and returned, or blocked or frozen? Which institution currently has or is processing it? Is sanctions screening the stated reason?
  3. If sanctions are mentioned, request the sanctions compliance or financial-crime team. Ask which jurisdiction or sanctions regime is relevant and whether the bank needs documents from you.
  4. Ask whether the funds are being returned, remain frozen, or are awaiting further information. Keep a dated record of the answers and any reference numbers.

International transfers can involve the sending and receiving banks, intermediaries, correspondent banks, and clearing institutions in different countries. The applicable rules can depend on those connections, the parties and their ownership or control, the payment purpose, and the measures in force. There is no single global process or universal deadline for resolving a sanctions-related payment.

Know the difference between a delay, rejection and block

Status What it generally means Practical next step
Pending or delayed The transfer has not completed, but that fact alone does not show why or establish that it is subject to sanctions. Ask the bank to trace it and identify the institution handling it and any information needed.
Rejected or returned Under OFAC’s explanation of US sanctions, a prohibited transaction may be rejected when there is no blocked person’s property interest. It is not processed and is returned to the originator. See OFAC FAQ 36. Ask the bank when and where the funds were returned, then reconcile the return with the sending account.
Blocked or frozen Under applicable US sanctions, blocking freezes property in which a blocked person has an interest. It is not the same as returning a payment. The bank or relevant authority must establish the status; do not infer it from a delay. Ask the institution holding the funds what process applies and, for a suspected US block, which institution filed the blocking report.

OFAC notes that a concrete wire instruction can create the relevant property interest; merely asking whether a payment is allowed does not itself create a blockable wire-transfer interest. See OFAC FAQ 53.

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Gather records before escalating

Keep copies of the original transfer instruction and confirmation, along with communications from every bank involved. OFAC’s guidance on applying to release blocked funds identifies original instructions and correspondence with the blocking institution among potentially relevant supporting documents. Organize:

  • Payment reference, date, amount, and currency.
  • Sender and beneficiary names and addresses as entered on the transfer.
  • Intermediary or correspondent bank details, including BIC information if available.
  • The invoice, contract, or other evidence explaining the payment’s purpose.
  • Bank notices, case numbers, and a log of calls or messages with dates and names or departments, where available.

Preserve the records as they are. Do not change party names or payment details to avoid screening.

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If a US OFAC block is confirmed

OFAC advises people who believe funds may be blocked to confirm the block with the financial institution first. Ask which institution filed the blocking report: OFAC generally does not process a release request without the corresponding report. OFAC also states, “OFAC itself does not seize or hold blocked funds.” The institution that blocked the property is therefore an important point of contact. See OFAC FAQ 51.

Depending on the facts and applicable sanctions program, an OFAC specific-license application may be a route to seek release. Review OFAC’s application help for release of blocked funds and prepare the transaction, parties, purpose, and supporting records. Applying is a request, not a promise that OFAC will authorize release. A US process applies only where the relevant US sanctions rules govern; it is not a universal route for international payments.

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If the issue concerns UK sanctions

UK financial sanctions licensing is governed by the relevant UK sanctions regulations and available legal grounds. Check OFSI’s current guidance on applying for a financial sanctions licence for the specific regime. OFSI can issue a licence only where legal grounds exist, and exceptions and licensing rules vary by regime. Do not assume that an OFAC application or a generic licence request will address a UK restriction.

For a complex, high-value, or cross-border case, qualified advice in the relevant jurisdiction can help identify which rules apply and whether a licensing route is available.

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Avoid workarounds and release-fee scams

  • Do not disguise parties, alter payment details, or resend the payment through another route to bypass screening. First establish the restriction and obtain appropriate advice or authorization; compliance rules may require a bank to block or reject a transaction.
  • Treat unsolicited offers to release frozen funds as potential fraud. OFSI says it will never request a payment, cryptocurrency transfer, or fee to obtain a licence or release frozen funds. Verify suspicious contact through OFSI’s guidance on checking communications claiming to be genuine, using contact details from GOV.UK rather than details in the message.

For UK reporting responsibilities and related guidance, consult OFSI’s general financial sanctions guidance.

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