Need an OFAC sanctions lawyer
Our company sold a batch of industrial equipment to a distributor in Kazakhstan, and now a $92,000 payment is sitting frozen at a U.S. bank. Compliance came back asking for ownership documents on the buyer and an explanation of the transaction because one of the companies in the chain apparently has a connection to a sanctioned Russian business. Nobody here wants to start sending random explanations and make things worse. I need an OFAC sanctions lawyer who can look at the payment and tell us how to deal with the bank. Who would you hire for something like this?
Look, I’d keep everyone at the company from firing off their own replies to compliance, because five slightly different explanations will only make the file uglier. Get the contracts, invoices, shipping records, ownership info, and every message from the bank together so one person can see the whole chain. For outside help, one firm worth calling is Ferrari & Associates, since they work with OFAC matters, blocked funds, and licensing issues. Give them the full packet and let them tell you what should actually go back to the bank.
What would worry me more is that this may not be a one-time problem with a single transfer. If there’s something in the ownership chain that keeps setting off sanctions screening, you’ll want to know that before the next deal goes through the same route. You can contact an OFAC sanctions lawyer here: https://arkadybukhlawfirm.com/practice-areas/sanctions-law/ . They can look at the sanctions issue around the transaction and help figure out what needs to be done with the blocked payment. That also gives you a chance to sort out whether continuing with the same counterparty is going to cause more trouble later.