The duration of an OFAC license depends on its type: General Licenses usually remain valid until officially revoked or amended, while Specific Licenses have a clearly defined period. After this period, continuing activities without license renewal may lead to serious legal consequences, including fines and blocked operations. Renewal requires timely submission of an application to OFAC with a set of documents confirming the necessity to continue the authorized operations. Errors in the application or missing the submission deadline can result in business interruptions and financial losses.
Our lawyers can help you prepare a renewal application in advance, collect all necessary evidence, and ensure full compliance with OFAC requirements. We know how to act quickly and efficiently so that your business does not face downtime or sanctions risks.
OFAC license duration: what you need to know
Under U.S. sanctions regulations, a key element of lawful operations with restricted jurisdictions, persons, or companies is having a valid license. Each license has a validity period, after which it must either be renewed or the sanctioned activity ceased. According to official U.S. Department of the Treasury – OFAC data, the license duration depends on its type and conditions set by the regulator.
Duration of a General License
A General License is a permit issued by OFAC in the form of an official document or a publication in the Federal Register, allowing certain categories of individuals and companies to carry out specific actions prohibited by sanctions without submitting an individual application.
Many General Licenses are indefinite until amended, suspended, or revoked by OFAC. However, there are temporary General Licenses with a limited validity period. For example, General License 13E (related to sanctions against Russia) was issued for several months with a specific expiration date.
Renewal is not initiated by companies; the decision is made by OFAC. Temporary licenses usually specify the exact expiration date and time (in U.S. time zones). After the expiration, performing previously authorized operations becomes a violation of the sanctions regime. Even if a General License is published as indefinite, it is necessary to monitor all OFAC updates, as it can be amended or revoked at any time.
Duration of a Specific License
A Specific License is an individual permit issued by OFAC to a particular person or company after submitting an application with justification.
In most cases, a Specific License is issued for one year from the date of approval. Other periods may be established depending on the nature of the authorized operations. For example, a license for a one-time transaction may only be valid until the completion of that particular deal.
To extend it, an application must be submitted in advance, usually 30–60 days before the expiration date. The renewal application must confirm that the conditions under which the license was issued remain valid. Late renewal means that any actions after the license’s expiration will be considered a violation of the sanctions regime with possible fines. Holders of a Specific License must independently monitor the expiration date and submit renewal documents on time to avoid interruptions in authorized activity.
What happens after a license expires?
If a company or individual continues transactions, operations, or other activities after the license expires, OFAC considers this a violation of the sanctions regime. Consequences can be serious:
- Financial penalties. Depending on the sanctions program violated, fines may reach tens or even hundreds of thousands of dollars per violation. For example, under some programs, the maximum fine exceeds $330,000 per episode;
- Criminal liability. In severe cases (intentional and systematic violations), criminal prosecution is possible, potentially resulting in imprisonment of up to 20 years and fines in the millions of dollars;
- Asset freezing. All funds and property related to the violation may be frozen, with access blocked until the investigation is complete;
- Reputational damage. Sanctions violations often become public, affecting relationships with banks, partners, and investors.
To avoid fines, criminal charges, and asset freezes, it is necessary to plan renewals or cessation of authorized operations in advance.
How to extend a Specific OFAC License
OFAC recommends submitting a renewal request at least 30 days before the license expires. In practice, it is optimal to do this 45–60 days in advance to avoid interruptions in operations. If the license has expired, performing operations covered by it is prohibited, even if the renewal application has already been submitted but not yet approved.
Where and how to submit a renewal request
The renewal request is submitted to OFAC via one of the following channels:
- Official OFAC License Application Page: the primary and fastest method. Requires creating or logging into an account, selecting the type of request (Renewal / Extension), and completing the electronic form;
- By email: to the address indicated in the license and on the OFAC website. The email must include a complete set of documents and a cover letter requesting renewal;
- By postal mail: to the Office of Foreign Assets Control, Licensing Division, U.S. Department of the Treasury, Washington, D.C. This method is slower and used only when online or email submission is not possible.
The letter must include the current license number, expiration date, and a clear justification for the renewal request.
Required documents
To renew an OFAC license, the applicant usually needs to provide:
- A copy of the current license;
- A completed renewal application (via portal or letter format);
- Justification for renewal: a description of ongoing operations, contracts, and obligations that cannot be completed within the current license period;
- Supporting operation documents (contracts, invoices, correspondence with counterparties, bank confirmations);
- Changes in transaction conditions (adjustments to amounts, participants, or deadlines);
- Evidence of compliance with license requirements — reports or confirmations that OFAC conditions were fully observed.
Tip: The more complete the document package, the higher the chances of quick processing.
Processing times
Renewal times depend on case complexity and OFAC workload:
- Standard cases: 2–4 weeks;
- Complex cases (involving multiple sanctions programs or international transactions): up to 60 days or more.
If a request is submitted less than 30 days before license expiration, there is a high risk of operational gaps. In some cases, OFAC may request additional documents or clarifications, extending the process. Therefore, it is important to submit the application in advance.
What to do if an OFAC license has expired
From the moment a license expires, all transactions, deals, and operations previously covered must be temporarily halted. This includes:
- Transfers of funds to or from a sanctioned jurisdiction;
- Export and import of goods and services authorized by the license;
- Any contractual obligations with individuals from the SDN list or other sanctioned entities.
Continuing operations without a valid license may result in fines up to $356,579 per violation and, in some cases, criminal liability.
It is necessary to notify OFAC of the situation and clarify possible actions. This is usually done via the OFAC license portal or by email. The letter must:
- Indicate the expired license number and expiration date;
- Briefly describe the reason the renewal was not submitted on time;
- Confirm the suspension of all operations;
- Request instructions for further actions.
In some cases, OFAC may issue a temporary or emergency authorization if operations need to be completed for legitimate reasons. This requires:
- A statement with a detailed description of the situation;
- Evidence that operations began before the license expired;
- Documents proving that completion is impossible without OFAC authorization.
OFAC may review compliance with previous license conditions and reasons for delay. It is crucial to retain all records and correspondence, maintain transparency in documentation, and confirm that no prohibited operations were conducted after the license expired.
Common mistakes when renewing a license
One of the most common mistakes is ignoring the exact expiration date. Some applicants submit documents too late, forgetting that a renewal application must be sent at least 30 calendar days before the expiration date. A delay even by one day will render the license invalid, making all covered operations illegal.
Even when the expiration date is known, internal approvals or lack of responsible personnel can lead to late submission. Assign someone to monitor licenses and use automated reminders.
Another frequent mistake is providing outdated information, such as obsolete contact details, old company data, or unupdated information about beneficiaries or partners. OFAC views such discrepancies as potential sanctions risks.
Some applicants limit themselves to general statements, failing to specify the types of activities and transactions requiring renewal. OFAC may request additional information, extending the process by weeks.
If violations occurred during the previous license, this almost certainly complicates renewal. Detailed explanations and evidence of corrective actions will be required.
OFAC provides clear instructions on where and how to submit renewal requests. Mistakes in choosing the submission channel can result in the application not being processed on time.
Conclusion: ensuring uninterrupted licensing
Under strict U.S. sanctions regulation, any delay in renewing an OFAC license may lead to a complete halt of operations, blocked transactions, and serious legal consequences. To avoid these risks, businesses should plan the renewal process in advance: start preparation at least 45–60 days before the license expires, carefully track dates, and maintain centralized documentation of all permits. Automating expiration alerts and central storage of all documentation minimizes human error.
Our lawyers can help establish a reliable license management system, renew licenses without delays, and protect your business from sanctions risks. Contact us now for consultation and a personalized action plan.