Frequently Asked Questions

661 … General License (GL) 9H authorizes U.S. persons to engage in all transactions prohibited by subsection 1(a)(iii) of Executive Order (E.O.) 13808 or by E.O. 13850 , each as amended by E.O. 13857 , or by E.O. 13884 , as collectively incorporated into the Venezuela Sanctions Regulations, 31 CFR… Read more

662 … General License 3I (GL 3I) authorizes U.S. persons to engage in all transactions related to, the provision of financing for, and other dealings in the bonds specified in the Annex to GL 3I (GL 3I Bonds) that would be prohibited by subsection 1(a)(iii) of Executive Order (E.O.) 13808 or by E.O… Read more

27 … This is primarily a question for your regulator. What constitutes an adequate compliance program depends in large part on who your customers are and what kinds of business you do. Certain areas of bank operations, such as international wire transfers and trade finance, are at a higher risk… Read more

28 … The frequency of running an OFAC scan must be guided by your organization's internal policies and procedures. Keep in mind, however, that if your organization fails to identify and block a target account (of a terrorist, for example), there could be serious consequences such as a transfer of… Read more

29 … There is no prepackaged compliance program that fits the needs of every bank. Banks, obviously, range in size from small to some of the largest institutions in the world. A good starting point is to go to the OFAC website and look under " Regulations by Industry ." Then read the brochure for… Read more

30 … The following information will provide you with areas to consider as you review your OFAC procedures . … How do I know if my compliance program is adequate? …

31 … There are a wide variety of software packages available to the financial community. The size and needs of each institution help to determine what to look for in a package. Some packages are used to interdict sanctioned countries and names on the Specially Designated Nationals or other… Read more

32 … Once it has been determined that funds need to be blocked, they must be placed into an interest-bearing account on your books from which only OFAC-authorized debits may be made. The blocking also must be reported to OFAC Compliance within 10 business days. Some banks have opted to open… Read more

33 … OFAC regulations require that funds earn interest at a commercially reasonable rate, i.e., at a rate currently offered to other depositors on deposits or instruments of comparable size and maturity. … How much interest do I have to pay on the blocked …

34 … Generally yes. In most cases (excluding Iraq, for instance) OFAC regulations contain provisions to allow a bank to debit blocked accounts for normal service charges, which are described in each set of regulations. The charges must be in accordance with a published rate schedule for the type of… Read more