OFAC General vs Specific Licenses Explained (2026)

A Texas medical equipment exporter needed to send diagnostic supplies to a hospital in Cuba in February 2026. The shipment value was $480,000 — far above the $5,000 threshold for personal emergency medical travel under General License 6. The company had seven business days to submit a specific license application before its Cuban counterparty canceled the contract.

OFAC issues two types of authorizations for transactions involving sanctioned countries, entities, or individuals. General licenses are self-executing blanket authorizations published in federal regulations — they apply automatically to anyone meeting the criteria, with no application required. Specific licenses, by contrast, are case-by-case written authorizations issued individually upon request after detailed justification and supporting documentation have been submitted and reviewed.

General license — any license or authorization the terms of which are set forth in Part 31 of the Code of Federal Regulations (31 CFR), automatically available to all persons who meet the criteria without requiring application or written approval from OFAC.

Specific license — any license or authorization not set forth in the regulations but issued pursuant to 31 CFR following a written application submitted to OFAC, granted individually to particular named entities for described transactions.

Key Takeaways

• General licenses operate automatically once you meet the published criteria—no application, no approval needed
• Specific licenses require detailed written applications through OFAC's portal and individualized review
• Before pursuing a specific license, you must first verify that no existing general license covers your transaction
• Most specific license applications require custom narrative submissions, not standardized forms
• If OFAC denies your application, there is no formal appeal process; reconsideration happens only if you submit genuinely new information that was unavailable when the original decision was made

What Are OFAC Licenses and Why Do They Matter for U.S. Businesses?

The Office of Foreign Assets Control is a Treasury Department division that administers economic sanctions programs based on U.S. foreign policy and national security objectives. OFAC regulations prohibit U.S. persons from engaging in most transactions with sanctioned countries, governments, entities, and individuals unless authorized by license or exemption. This reach extends beyond U.S. borders—the restrictions apply to U.S. citizens, permanent residents, and U.S.-incorporated entities regardless of where they operate globally.

Violating these restrictions carries real teeth. Civil penalties range from $250,000 to over $10 million per violation, depending on the sanctions program and whether the violation was willful. Willful violations can trigger criminal fines up to $1 million and imprisonment for up to 20 years. OFAC licenses are what let you proceed legally when you would otherwise be prohibited.

Two distinct authorization mechanisms exist, and knowing which applies determines your next move. One lets you act immediately. The other requires you to wait weeks—or months.

What Is an OFAC General License and How Does It Work?

Under 31 CFR § 595.305, a general license is "any license or authorization the terms of which are set forth in this part." The Cuba sanctions program publishes these in 31 CFR Part 515, Iran sanctions in Part 560, and so on across multiple CFR sections. Each regulation contains its own general license menu.

Self-executing. That's the core concept. General licenses apply automatically to broad categories of persons and transactions without any application, approval process, or written confirmation from OFAC. Your transaction meets the published criteria? You're authorized. The authorization comes from the regulation itself, not from a document OFAC issues to you.

Humanitarian donations, educational materials, First Amendment-protected informational materials, personal remittances below specified thresholds, certain authorized travel, and transactions involving specific blocked property are common general license categories across sanctions programs. Cuba's regulations alone include General License 6 (support for the Cuban people), General License 15 (professional meetings), and General License 20 (humanitarian projects).

Each license spells out exactly who qualifies, which transaction types are covered, any financial caps, required conditions, and prohibited items. A Cuba gift-parcel license might allow $400 per month but exclude electronics. Exceed the threshold or include a prohibited item? The general license no longer covers you.

Do I need to apply for a general license?

No. OFAC does not accept or review applications for authorizations already published in the regulations. Your job is self-assessment: determine whether the published criteria fit your transaction, confirm you meet every condition, and proceed.

What you cannot skip is documentation. You must keep records proving your transaction complied with general license terms—contracts, invoices, correspondence, internal compliance notes. OFAC can audit your activity years later, and you carry the burden of proof. Retain these records for at least five years.

If a general license requires advance notification or post-transaction reporting, those deadlines are not optional. Missing a reporting deadline converts an otherwise authorized transaction into a violation.

Can I use a general license for any sanctioned transaction?

Only for the specific activities and beneficiaries each license describes. A Cuba program general license does not authorize Iran transactions. A materials license does not cover agricultural exports. Scope creep is one of the most common compliance mistakes.

If your transaction value exceeds the cap, involves parties outside the authorized class, or includes activities the license does not cover, the general license provides zero protection. At that point you have two choices: restructure the deal to fit within the general license parameters, or apply for a specific license.

Talk to our sanctions compliance team if you're unsure whether a general license covers what you want to do—uncertainty offers no protection in enforcement.

What Is a Specific License and When Do You Need One?

OFAC defines a specific license in 31 CFR § 595.312 as "any license or authorization not set forth in this part but issued pursuant to this part" after written application and review. Unlike general licenses, specific licenses are one-off. They go to one named applicant for specific transactions only. Your competitor cannot use your license. You cannot use it for deals outside its scope.

OFAC issues specific licenses only after written application, individualized review, and affirmative approval. The agency evaluates whether the transaction would align with U.S. foreign policy and national security objectives. OFAC has complete discretion to approve, deny, or condition approval on additional requirements.

You need a specific license when no general license covers your transaction or when you exceed general license parameters. Commercial exports or imports above gift thresholds, investments in sanctioned jurisdictions, financial services for blocked entities, complex humanitarian projects outside general authorizations—these commonly require specific licenses. Some general licenses explicitly state that certain sub-categories demand separate authorization.

Processing timelines are unpredictable. Straightforward humanitarian authorizations might take weeks. Complex commercial transactions or sensitive-jurisdiction deals can stay under review for months. OFAC publishes no guaranteed timelines and does not fast-track applications based on business urgency. The Texas exporter with a seven-day contract deadline faces real risk.

How do I know if I need a specific license or if a general license covers my transaction?

Take three systematic steps. First, identify every sanctions program touching your transaction by examining the countries, entities, and individuals involved. Check the Specially Designated Nationals and Blocked Persons List (SDN List) and all country-based programs that might apply.

Second, read every general license in the relevant CFR part. They are typically numbered sequentially. For each one, assess whether your transaction falls entirely within its scope. Watch for exclusions and conditions—a license that seems to fit might exclude your specific activity or impose reporting obligations you missed.

Third, if no general license fully covers what you want to do, or if you exceed any quantitative or qualitative limit, pursue a specific license. Uncertain? OFAC compliance staff can offer informal guidance on whether a general license applies—but that guidance is not legal authorization and cannot shield you if OFAC later decides your interpretation was wrong.

How Do You Apply for an OFAC Specific License?

Start here: OFAC's online licensing portal is the only way in. Mail and email don't work. You'll find it through the Treasury Department website, but you need to register an account first.

One surprise for new applicants—OFAC doesn't hand you a form. You write a detailed narrative instead. That narrative has to cover the transaction itself, who's involved, why you think OFAC should approve it, and what policy goal it serves. The key: show OFAC that approving your license strengthens rather than undermines their sanctions objectives.

What information does OFAC require in a specific license application?

OFAC wants to know everything about you first. Your full legal name, address, citizenship or incorporation status, contact information for decision-makers, and (if you're a corporation) your ownership structure and any foreign affiliates. They're checking whether you yourself are blocked or restricted.

Next, name every party to the deal. For each counterparty: full legal name, address, jurisdiction of organization, and whether any government officials own or manage it. This is where OFAC catches indirect sanctions-busting—they're making sure your authorized transaction doesn't secretly benefit someone sanctioned.

Describe the transaction itself. What exactly are you selling or transferring? How much? How will it be paid? When does each side perform? For exports, include HS codes and destination. For financial transfers, specify originating and receiving banks, purpose, and end use.

Attach supporting documents—contracts, invoices, correspondence, corporate formation papers, financial statements. For humanitarian work, add project plans and beneficiary documentation.

The legal justification section is your argument. Cite the statutes or regulations you think authorize the deal and explain how it serves U.S. interests. Humanitarian justifications land better with concrete evidence. Commercial justifications should connect to U.S. economic benefit or policy goals like civil society support.

How long does it take OFAC to approve a specific license?

There's no guarantee. OFAC works case by case. Straightforward deals under established policies might move in four to eight weeks. But complex deals, sensitive countries, large dollar amounts, or anything requiring interagency sign-off can stretch to several months.

Here's what actually happens: you submit your application, then you wait without updates unless OFAC asks for more information. When they do ask, the clock essentially restarts—your approval date resets to 4-8 weeks from your supplemental submission. Calling OFAC repeatedly about your status won't move it faster.

If OFAC leans toward approval but wants conditions, they'll draft a license for you to review. You can negotiate some terms, though OFAC has the final say.

The practical timing issue: if you're planning a deal dependent on OFAC approval, build in a 3-6 month buffer unless your transaction is genuinely routine. Deals that seemed fast in hindsight usually weren't rushed—they just happened to land on an uncrowded desk.

Key Differences Between General and Specific Licenses

General licenses are automatic. They're published in the CFR and activate the moment you meet their criteria—no application, no waiting, no OFAC approval required. Specific licenses are the opposite: you apply, OFAC reviews, and only if they say yes does it activate.

That means the application process is night and day. General: nothing. Specific: weeks or months of review, plus complete documentation.

Scope matters too. A general license covers any person who fits the published description—it's broadly available. A specific license covers only you, only for the exact transaction you described. You can't hand it to someone else, transfer it, or use it for anything outside its terms.

Which type applies to you? If a published general license covers your deal, use it—you're done immediately. Specific licenses are for everything else: transactions that exceed general license limits, activities a general license explicitly excludes, or situations with no general license at all. Most routine personal transactions, small humanitarian donations, and information sharing fit under general licenses. Complex commercial deals, large transfers, and uncovered activities need specific licenses.

What Happens If OFAC Denies Your Specific License Application?

Denials happen when OFAC thinks the deal conflicts with sanctions goals, involves problematic parties, creates diversion risk, or lacks policy justification. Denial letters give reasons, but not always detailed ones—classified intelligence or foreign policy sensitivity often means you get a vague explanation.

There is no formal appeal. OFAC will reconsider only "for good cause"—meaning new information that wasn't available before and that materially changes their analysis. Restating your old arguments better won't do it.

You have to prove circumstances changed. Acceptable reasons for reconsideration: the counterparty changed ownership, the transaction structure shifted, or U.S. policy moved (new general licenses, policy statements loosening restrictions). Your reconsideration request must explicitly say what new information exists, why it wasn't available originally, and why it changes the answer.

OFAC uses three categories: denied (final no), returned without action (incomplete or seeking authority already in general licenses—can be resubmitted), and pending (still under review). Silence isn't denial.

If denial sticks, consider restructuring. Reduce the dollar amount, switch counterparties, or narrow scope to fit a general license. Or wait—OFAC sometimes relaxes rules in response to policy shifts.

Can I reapply if my specific license is denied?

Reapply only if the new application looks materially different: different facts, different counterparties, restructured transaction with different policy angles. Resubmitting the same thing with better writing won't work.

For reconsideration requests, document that the new information couldn't have been included in the original application—it didn't exist, wasn't discoverable through reasonable effort, or came from changed circumstances after denial. New OFAC policy statements, regulatory changes, or documented shifts in counterparty ownership qualify.

Timing counts. File for reconsideration soon after new information emerges. Waiting months undermines claims that the information is material. Write a cover letter explicitly requesting reconsideration for good cause, cite your original application and denial date, and clearly separate the new information from your old argument.

This article is published by an independent law firm for informational purposes only and does not represent or claim affiliation with any government body, international organization, or official authority.

Frequently Asked Questions About OFAC General and Specific Licenses

What is the difference between a general license and a specific license?

General licenses work automatically. You don't apply, don't wait for approval—the authorization exists the moment you meet the published criteria. Specific licenses require you to submit a detailed written application naming your company and describing your exact transaction, then wait for OFAC to review and issue individualized permission. In practice: a general license is like a posted speed limit everyone can use immediately; a specific license is like asking the police for permission to drive faster on a particular day.

Do general licenses expire?

They don't have expiration dates the way specific licenses do. General licenses stay valid as written in the Code of Federal Regulations unless OFAC formally changes or cancels them through Federal Register notice. That permanence is the upside. The catch: OFAC can narrow the scope, tighten the conditions, or kill a general license entirely at any time through rulemaking. You need to check for updates regularly—especially if you're relying on the same general license year after year—because the rules you followed last quarter might have shifted.

Can OFAC revoke a specific license after it has been issued?

Yes. Once issued, OFAC retains the power to revoke, suspend, or modify a specific license if you violate its terms, if you lied or misled on the application, or if U.S. policy changes and OFAC determines the authorization no longer serves national interests. Most specific licenses include boilerplate language explicitly stating OFAC can do this without warning. Revocation takes effect immediately when you get the notice—not 30 days later, not after you finish the transaction you're mid-way through. This is why reading the full terms and conditions of any specific license matters.

How long are recordkeeping requirements for transactions under general licenses?

Keep records for at least five years from the transaction date. That applies to both types of licenses. For general licenses specifically, the documentation matters enormously: you'll need proof that you actually met every single criterion when the transaction occurred. OFAC audits can happen years after the fact, and the burden falls on you to show compliance. If your records are sparse or unclear, you can't easily demonstrate you weren't breaking the law at the time.

What should I do if I am not sure whether a general license covers my transaction?

Start with the actual regulation. Don't rely on summaries, blog posts, or third-party explanations—go directly to the Code of Federal Regulations text, which is the only legally binding authority. Next, check OFAC's published FAQs and guidance documents; they often clarify edge cases that trip people up. Still stuck? Contact OFAC's Sanctions Compliance and Evaluation Division through the Treasury website with a detailed written description of what you want to do. Their informal guidance won't protect you in a penalty case, but it does show you acted in good faith—which regulators notice. When the transaction is large, time-sensitive, or strategically important, skip the guesswork and apply for a specific license instead. You'll get written authorization on paper and sleep better.