Scenario: Agent Holds Frozen Funds

The frozen-funds scenario - hold, log, report.

The setup

An address your agent controls - or a payment it was about to make - becomes frozen: designated by OFAC, or frozen by issuer/exchange action.

What holding means

• The funds are blocked property - you hold, you do not transact
• Unfreezing without authorization is itself a violation
• You report per obligations (blocking reports within 10 days)

The workflow

1. Identify the freeze (screening match, issuer notice, exchange notice)
2. Block related payments and hold the funds
3. Document: list version, decision, review
4. Report per obligations; seek counsel for release requests

The takeaway

Frozen is a state, not a loss - hold, log, report. The freezing post covers the mechanisms.