John, a U.S. citizen, had been doing business with a company called XYZ Inc., which was based in a country subject to U.S. sanctions. Unbeknownst to John, XYZ Inc. was actually owned and controlled by an individual named Ali, who was on the SDN list.
Blocking is not forfeiture. Forfeiture requires a separate judicial proceeding (civil or criminal). Until forfeiture occurs, the funds belong to the SDN. who do blocked funds on the sdn list belong to