I have reviewed the OFAC regs and didn't see anything relating to access to lines of credit. If you identify a sanctioned indvidual with checking/savings/etc accounts those funds must be blocked. If that person also has lines of credit: ELOC, credit cards, etc. should access to the credit also be blocked. Logic seems that this is true, but again I didn't see anything in the regs. addressing this
Jim

I believe that the Sanction programs mention all assests must be blocked. As you stated, logic would dictate that a LOC would fit this category and must be blocked.

If your not sure, I would recommend calling OFAC to seek their opinion on the matter.