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- Audit and consulting clients include: Aruba Bank, Banco Agricola, Fiserv, Global Cash Access, Keefe, and SafetyPay
- Training clients include: Bank of America, Capital One, Charles Schwab, Moneygram, Scotiabank, and UBS
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The Office of Foreign Assets Controls (OFAC) is an agency within the U.S. Treasury Department. It enforces laws that apply to all U.S. businesses, large or small, in regards to economic and trade sanctions imposed on:
- Specific countries and geographic regions targeted by the U.S. government.
- Companies owned, controlled or acting on behalf of targeted countries.
- Foreign individuals and entities who are not country-specific – but targeted because they are terrorists, international narcotics traffickers or people involved with weapons of mass destruction.
U.S. companies are prohibited from engaging in financial transactions with OFAC-targeted countries, businesses or individuals. OFAC laws also apply to foreign financial institutions that conduct U.S. dollar transactions.
Collectively, the individuals and companies targeted by OFAC are called "specially designated nationals," or SDNs. OFAC publishes a list of these SDNs and it includes more than 6,000 names of companies and individuals worldwide. No matter where SDNs are located at any given time, OFAC prohibits transactions with them.
Multimillion-dollar fines have been imposed on institutions that did not comply with OFAC laws.
Wal-Mart, Geico, the New York Yankees, ChevronTexaco and ESPN are among companies that have settled charges of illegal trading with countries such as Iraq, Cuba and others.
Examples of prohibited transactions:
- A U.S. financial institution allows a customer to wire transfer funds to his family in Libya.
- A U.S. broker-dealer opens a margin account and executes trades for a new customer and subsequently learns the customer is a "specially designated national."
- A U.S. insurance company issues a property insurance policy to an international corporation that maintains a factory in Iran.
- A U.S. exporter sends licensed goods to Myanmar, but pays a dock fee not allowed under the sanction program.
- A U.S. airline transports unlicensed goods to Iran.
- Employees of a U.S. magazine paid for their hotel and other travel-related expenses while on a photo shoot in Cuba, but without the license that OFAC requires for certain activities or business dealings.
- A U.S. citizen makes a contribution to Benevolence International Nederland, a designated terrorist organization.
How can a company know if it is in compliance with OFAC sanctions? The Best Practices detailed below can keep your company safe from exposure that could damage your reputation and your bottom line.