To require the Office of Foreign Assets Control to develop a program under which private sector firms may receive a license to conduct nominal financial transactions in furtherance of the firms’ investigations, and for other purposes.
Sponsors
Joyce Beatty
D-OH | Primary Sponsor
Legislative Progress
Passed HouseReceived; read twice and referred to the Committee on Banking, …
Passed House (inferred from eh version)
Reported from the Committee on Financial Services
Committee on Foreign Affairs discharged; committed to the Committee of …
Mrs. Beatty (for herself and Mr. Nunn of Iowa) introduced …
Summary
What This Bill Does
The OFAC Licensure for Investigators Act creates a 5-year pilot program that allows private sector investigation firms to apply for special licenses from the Office of Foreign Assets Control (OFAC) to conduct small financial transactions that would normally be prohibited under U.S. sanctions. This enables investigators working on financial crimes to interact with sanctioned entities when necessary for their investigations.
Who Benefits and How
Private investigation firms, compliance consultants, financial forensics companies, and law firms with investigative practices benefit by gaining legal authorization to conduct investigative work that requires limited interactions with sanctioned entities. This removes a significant barrier that previously prevented them from taking on certain cases or completing investigations involving sanctioned jurisdictions. These firms can now expand their service offerings and take on more complex international financial crime investigations.
Who Bears the Burden and How
The Office of Foreign Assets Control (OFAC) bears the primary burden, as it must establish and administer the new licensing program, process applications, review monthly reports from licensed firms, and submit annual reports plus classified briefings to Congress. Licensed firms face monthly reporting requirements documenting all activities conducted under their licenses, creating administrative overhead. The Financial Crimes Enforcement Network (FinCEN) must coordinate with OFAC on program implementation.
Key Provisions
- OFAC must establish the pilot licensing program within 1 year of enactment
- Private firms conducting investigations can apply for licenses to conduct "nominal" financial transactions with sanctioned entities
- Licensed firms must submit detailed monthly reports to OFAC on all activities conducted under the license
- OFAC must submit annual reports to Congress containing the number of licenses requested/granted and the utility of the program
- OFAC must provide classified briefings to Congress with detailed information on applicants, operations, and recommendations
- The pilot program automatically terminates 5 years after it is established
- OFAC must coordinate with FinCEN to support Financial Crimes Enforcement Network Exchange activities
Evidence Chain:
This summary is derived from the structured analysis below. See "Detailed Analysis" for per-title beneficiaries/burden bearers with clause-level evidence links.
Primary Purpose
Establishes a 5-year pilot program allowing private sector investigative firms to obtain licenses from OFAC to conduct nominal financial transactions in support of their investigations
Policy Domains
Legislative Strategy
"Create a controlled exemption mechanism for private investigators to conduct limited financial transactions with sanctioned entities when necessary for investigations"
Likely Beneficiaries
- Private investigation firms conducting financial crime investigations
- Compliance consulting firms
- Law firms with investigative practices
- Financial forensics companies
Likely Burden Bearers
- OFAC (administrative burden of managing new licensing program)
- FinCEN (coordination requirements)
- Licensed firms (monthly reporting requirements)
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
- "the_director"
- → Director of the Office of Foreign Assets Control (OFAC)
- "the_director_of_fincen"
- → Director of the Financial Crimes Enforcement Network (FinCEN)
Key Definitions
Terms defined in this bill
Firms engaged in investigations that may require conducting financial transactions that would otherwise be restricted by OFAC sanctions
We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.
Learn more about our methodology