Frequently Asked Questions

1180. What changes did OFAC make in the June 5, 2024 regulatory amendments to the Syrian Sanctions Regulations, 31 CFR part 542 (SySR)?

1180 … On June 5, 2024, OFAC, in consultation with the Department of State, amended the SySR to, among other things, incorporate certain sanctions statutes, including the Caesar Syria Civilian Protection Act of 2019, which are designed to deny the Assad Regime the resources it needs to support its… Read more

1181. Effective June 12, 2024, how is Treasury interpreting Russia’s military-industrial base under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?

1181 … In line with G7 commitments and in response to the Government of the Russian Federation’s continued efforts to reorient its economy and government resources to support its war effort, Treasury has updated its definition of Russia’s military-industrial base to include all persons blocked… Read more

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

44 … There is no minimum or maximum amount subject to the regulations. … Is there a dollar limit on which transactions are subject to OFAC regulations? …

45. 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 Specially Designated Nationals list? Do I need to check their names against all of OFAC's other sanctions lists?

45 … Every transaction that a U.S. financial institution engages in is subject to OFAC regulations. If a bank knows or has reason to know that a target is party to a transaction, the bank's processing of the transaction would be unlawful. … Does my bank need to check the OFAC list when selling… Read more

46. If a loan meets underwriting standards but is a true "hit" on OFAC's Specially Designated Nationals (SDN) list, what do we use as a denial reason on the adverse action notice?

46 … If you have confirmed with OFAC that you have a "good hit" on the SDN list or one of OFAC's other sanctions lists , there is no reason not to explain that to the customer. The customer can contact OFAC directly for further information. … If a loan meets underwriting standards but is a true "… Read more

47. 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?

47 … Donations to charitable institutions must be handled as any other financial transaction. The donating bank or institution should crosscheck the recipient names against OFAC's sanctions lists and assure that the donations are in compliance with OFAC sanctions programs . … Through corporate… Read more

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

52 … Yes, U.S. financial institutions are authorized to open correspondent accounts for, and process funds transfer to or on behalf of Iraqi financial institutions. … Can U.S. financial institutions open correspondent accounts for Iraqi financial institutions, or process funds transfers to and from… Read more

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

95 … "Property," as defined in OFAC regulations, includes most products that financial institutions offer to their clients. "Property interest," as defined by OFAC, includes any interest whatsoever, direct or indirect, present, future or contingent. Given these definitions and as a matter of sound… Read more

335. Firms operating in the securities industry as custodians and securities intermediaries often face the question of how to accurately identify the beneficial owner of assets within an account or transaction. What can these firms do to protect themselves from the risk of directly or indirectly providing services to—or dealing in property in which there is an ownership or other interest of—parties subject to sanctions?

335 … OFAC encourages firms operating in the securities industry, including securities intermediaries and custodians, to implement measures that mitigate the risk of providing services to, or dealing in property in which there is an ownership or other interest of, parties subject to U.S. sanctions… Read more

559. For purposes of OFAC sanctions programs, what do the terms "digital currency," "digital currency wallet," "digital currency address," and "virtual currency" mean?

559 … Digital currency includes sovereign cryptocurrency, virtual currency (non-fiat), and a digital representation of fiat currency. A digital currency wallet is a software application (or other mechanism) that provides a means for holding, storing, and transferring digital currency. A wallet… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence