OFAC Flashcards
What is a OFAC blocked account
Account with payments, transfers, withdrawals that must be made with authorization from OFAC
What is blocking
Also called freezing .. controlling accounts assets under US Jurisdiction
What is a National
A subject or citizen of a country who has lived in or been a permanent resident of the country since the effective date
Person subject to the Jurisdiction of the United States
The univers of persons and entities that must comply with OFAC regulations
Who must comply with OFAC regulations
All us persons
What does OFAC regulations require banks to do
Block accounts and other property interest of specified countries, entities, individuals
Prohibit or reject unlicensed trade and financial transactions with specified countries, entities, and individuals
Banks must block transactions that are
By or on behalf of a blocked individual
Go through a blocked entity
Are in connection with a transaction with a blocked individual or entity
When should a report on blocked accounts or rejected transactions be sent to OFAC
Within 10 days of the occurrence
What information is required to be sent for a blocked assets
Identification of the property
Owner of the account
Property address
Account Number
Value of the account
Blocking date
Name and address of the holder
Name and address of compliance personnel
Information to be retained for rejected transactions include
Name of financial institution requesting the transfer
Date and amount of transfer
Photocopy of transfer instructions
Reason for the rejection
Name of compliance personal
What may OFAC do if a transaction should have been blocked
Request information on how the transaction was processed
How many days does a bank have to respond to a OFAC letter
The bank has 30 days to reply and request no penalty
How often must a annual report on blocked accounts be filed
Blocked accounts as of 6/30 must be filed by 9/30
What type of account bust blocked accounts be placed in
Interest bearing account earning interest at a commercially reasonable rate
How long must a bank keep its record of rejected transactions
5 years
