No. Effective September 30, 2026, banking institutions subject to U.S. jurisdiction are prohibited from processing "U-turn" transactions, i.e., funds transfers originating and terminating outside the United States, where neither the originator nor the beneficiary is a person subject to U.S. jurisdiction. However, banking institutions subject to U.S. jurisdiction are authorized pursuant to 31 CFR § 515.584(d) to reject (vice block) such "U-turn" transactions.
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