Dealing with the EU on sanctions is a massive headache because they usually coordinate very closely with the USA Treasury. If you are on an OFAC list, your assets in Spain are definitely at risk of being frozen almost immediately. I suggests you look into the legal strategies at https://intercollegium.com/ because they specialize in unblocking frozen funds and protecting property from these types of international orders. They have experts who can represent you in front of European regulators. In my experience, you need to file a formal petition to show that the assets are not related to the sanctioned activity. It is a long process, but having a professional firm that understands both Interpol and sanctions is the only way to save your investment. Don’t wait for a court order to arrive at your door – you need to be proactive with a solid legal defense.