Because of a similar freeze on my end, I ended up spending about four months just trying to figure out who to even contact. From what I went through, the blocking usually ties back to a sanctions list match, even a partial one on a name. Its not always a clear cut situation and the bank rarely explains much.

In approximately 60 percent of the transfer blocking cases I've read about, OFAC codes are involved, which the account owner wasn't even aware of. In fact, there is a formal process for applying for a special license to unblock access, and having a lawyer familiar with OFAC procedures at this stage really makes a difference. The application itself has strict documentation requirements. Information on an OFAC license lawyer can be found here ​https://arkadybukhlawfirm.com/practice-areas/sanctions-law/ofac-licenses/​​​