Compliance with OFAC Regulations for Wiring Cash to a Specially Designated National

Compliance with OFAC Regulations

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Question

FA presents cash to the bank and seeks to wire it to his spouse, RA, in Cub A. The OFAC list identifies RA as a specially designated national. Under OFAC

Regulations, what should the bank do?

Answers

Explanations

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A. B. C. D.

A

The Office of Foreign Assets Control (OFAC) is a US government agency responsible for enforcing economic and trade sanctions against countries, entities, and individuals that pose a threat to national security or foreign policy interests. The OFAC maintains a list of Specially Designated Nationals and Blocked Persons (SDN List), which includes individuals, organizations, and countries subject to various economic sanctions.

In the given scenario, FA wants to wire cash to his spouse, RA, who is identified on the OFAC SDN list as a specially designated national. Therefore, the bank needs to comply with the OFAC regulations to avoid any potential penalties or legal repercussions.

Option A - Block the transfer: OFAC regulations prohibit any US financial institution from conducting transactions with individuals or entities on the SDN list. Therefore, the bank should block the transfer immediately to avoid any violation of OFAC regulations.

Option B - Conduct the transfer as requested and take no further action: Conducting the transfer as requested would violate OFAC regulations as RA is an SDN, and the bank could face significant fines and penalties for facilitating such transactions.

Option C - Conduct the transfer as requested and notify OFAC immediately: This option is incorrect because OFAC regulations prohibit any US financial institution from conducting transactions with individuals or entities on the SDN list. The bank should not conduct the transfer and instead block it immediately.

Option D - Conduct the transfer only if the bank determines that Cuba is not a blocked country: This option is also incorrect because OFAC regulations prohibit any US financial institution from conducting transactions with individuals or entities on the SDN list, regardless of the country's status.

In summary, the correct answer is Option A - Block the transfer, as OFAC regulations prohibit US financial institutions from conducting transactions with individuals or entities on the SDN list.