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A OFAC allows a credit union to choose either method. Once it has been determined that funds need to be blocked (i.e., frozen), they must be placed into a dividend- or interest-bearing account on the credit union’s books from which only OFAC-authorized debits may be made.
Some financial institutions open separate accounts for each blocked party while others opt for an “omnibus account” to house funds from all blocked accounts. Either method is permissible as long as there’s an audit trail that will allow specific funds to be unblocked with interest at any point in the future.