International Trade Compliance Institute

Export Start-Up Kit

Trade Information Database

Regulatory FAQs

Regulatory Database

Q&As for Export Counselors
and Companies

Book - Roadmap To Export Success

U.S. National Security Export Controls/FAC: Financial Institutions

Does OFAC itself require that banks set up a certain type of compliance program?

How do I get the OFAC Starter Kit?

What do I need to do to comply? Do I have to buy expensive software?

How often do I need to scan my customer database for SDNs?

How do I setup a compliance program for my bank?

How do I know if my compliance program is adequate?

What are the features and benefits that banks should be looking for when selecting an OFAC compliance software package?

How do I block an account or a funds transfer?

How much interest do I have to pay on the blocked funds?

Can my bank deduct service charges from the account?

Do all OFAC programs involve blocking transactions?

I understand blocking a transaction, but what is meant by rejecting a transaction? When should a transaction be rejected rather than blocked?

My bank operates accounts for individuals living in Iran. OFAC has told us that these accounts cannot be operated. Does this mean that the accounts are blocked?

Are U-Turn payments for Iran still permitted?

What do I do if I have a blocked account that needs to be escheated to the state?

If my financial institution receives a wire going to an embassy in a sanctioned country, can we process the transaction?

Should an institution tell its customer that it blocked their funds, and, if so, how does the institution explain it to them?

What do I do if a person tries to open an account and the person's name is on OFAC's SDN list? Do I open the account and then block the funds?

Does a financial institution need to scan names against OFAC's list of targets upon account opening or can it wait for 24 hours to receive a report from its software vendor on whether or not there is a hit?

Is there a dollar limit on which transactions are subject to OFAC regulations?

Does my bank need to check the OFAC list when selling cashier's checks and money orders? In the case of cashier's checks, do I need to check both the purchaser and the payee? As a mortgage lender, do I need to check both the purchaser and the seller's name against the SDN list?

If a loan meets underwriting standards but is a true 'hit' on the OFAC list, what do we use as a denial reason on the adverse action notice?

Through corporate giving programs, many banks contribute toward charities and other non-profits. To what extent does a bank need to review the recipients of these gifts or the principals of the charities?

I just received an interdiction 'alert.' What do I do?

When a transaction is rejected or blocked, I have ten days to report it. Do I have to do it in writing or can I call OFAC Compliance and report it that way?

Is there a requirement for annual reporting of blocked property? Is there a required format?

How do I apply for a license to get my money unblocked?

Can U.S. financial institutions open correspondent accounts for Iraqi financial institutions, or process funds transfers to and from Iraqi financial institutions?

How do I differentiate between an 'inquiry' and a 'payment instruction' when a customer wants to send a wire transfer to a sanctioned party or country?

I have an account with a W-8 showing an address in Iran. Is the account automatically restricted?

Does a financial institution have the obligation to screen account beneficiaries for compliance with OFAC regulations?

Does OFAC have an exporter assistance phone line?

What is the difference between the SDN List and the Commerce Department's List of Denied Parties? Why can't they be integrated into one list?

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