Under Office of Foreign Assets Control (OFAC) rules, a financial institution managing blocked funds:

OFAC regulations require that blocked funds must be placed into an interest-bearing account, held separately, and reported to OFAC. This does not require preauthorization from OFAC.

However, no debits or credits may occur without OFAC authorization, including:

• settling standing bills or checks (A),

• charging interest or loan/corporate card fees (C),

• deducting credit-card service charges (B).

Only OFAC can authorize movement or use of blocked property.