Who must file for a Specific License according to OFAC regulations?

Filing for a Specific License under the Office of Foreign Assets Control (OFAC) regulations is mandated for any person or entity that wishes to engage in transactions that are otherwise prohibited due to sanctions. This broad definition includes not just banks but also any individuals or businesses that find themselves wanting to conduct activities involving blocked individuals or countries.

The core purpose of a Specific License is to allow transactions that are not generally permitted under the current sanctions regime, provided that they have been reviewed and authorized by OFAC. This means that any person with an interest in a transaction – which could include individuals, small businesses, and large corporations alike – has the ability to seek permission through the licensing process.

The other options tend to restrict the eligibility for filing a Specific License inappropriately. For instance, stating that only banks or only large corporations can file would limit the access for other stakeholders, such as small businesses or individual investors, who may also have legitimate reasons for requiring a specific license to continue a transaction. Hence, the inclusive nature of the correct answer reflects the essential purpose of OFAC regulations, which is to ensure compliance across a wide array of entities and individuals.