Is Turkey part of OFAC?

On June 5, 2020, the U.S. Office of Foreign Assets Control (OFAC) issued a final rule implementing sanctions against Turkey originally published in Executive Order 13894, entitled “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria.” OFAC originally imposed and subsequently …

Are banks subject to OFAC?

Every transaction that a U.S. financial institution engages in is subject to OFAC regulations. If a bank knows or has reason to know that a target is party to a transaction, the bank’s processing of the transaction would be unlawful.

What is OFAC list in banking?

OFAC Sanctions Lists OFAC publishes lists of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific.

What does OFAC require of banks?

OFAC is not itself a bank regulator; its basic requirement is that financial institutions not violate the laws that it administers. Financial institutions should check with their regulators regarding the suitability of specific programs to their unique situations.

Who is subject to OFAC requirements?

All U.S. persons must comply with OFAC regulations, including all U.S. citizens and permanent resident aliens regardless of where they are located, all persons and entities within the United States, all U.S incorporated entities and their foreign branches.

What transactions are subject to OFAC?

Transactions that are Subject to OFAC

• Deposit (checking & savings) accounts.
• Loans.
• Credit Cards.
• Wire transfers.
• ACH transfers.
• Lines of credit.
• Trust accounts.
• Loan payments.

What are 3 types of OFAC sanctions?

OFAC Economic Sanctions Programs

• Diplomatic;
• Criminal Enforcement;
• Economic;
• Humanitarian; and.
• National Security.

What is KYC OFAC?

The Office of Foreign Asset Control (OFAC) is a department of the U.S. Treasury that is charged with enforcing economic and trade sanctions imposed by the U.S. against countries and groups of individuals.

What is OFAC AML?

Established in the 1950s, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury administers and enforces sanctions based on the foreign policy against targeted foreign countries and other threats to national security.

When did British Arab Commercial Bank settle with OFAC?

OFAC’s September 17, 2019 settlement with UK-based British Arab Commercial Bank (BACB) demonstrates how challenging and complex it can be to assess whether offshore transactions in US dollars (USD) that involve US sanctions targets are in all respects outside of OFAC’s enforcement jurisdiction.

Is the British Arab Commercial Bank a US Bank?

BACB, of course, is not a US financial institution, and no US financial institutions have yet been penalized in this matter. OFAC stated that “BACB and Bank B ensured that the USD transactions with its Sudanese clients occurred outside of the United States and without knowledge of BACB’s or Bank B’s USD correspondents.”

Is the US Treasury under the jurisdiction of OFAC?

By way of background, senior Treasury Department (Treasury) officials have stated on the record that OFAC’s jurisdiction does not extend to the use of the USD itself.

What was the basis of the OFAC case against BACB?

To be clear, there were US financial institutions that processed the payment transactions used to fund BACB’s offshore nostro account, which formed the basis for OFAC’s determination that it had the authority to bring this case.