BSA/AML Examiner School - December 2022

12/1/2022

Internal Use Only

OFAC – Sanctions Update U.S. has limited trade activity with Russia

Designed a three ‐ pronged search: 1. Check to see if on SDN list 2. Sanctions on parts of Ukraine – transactions should be rejected 3. Directive – making it hard for businesses

9

Internal Use Only

OFAC – Sanctions Update

Blocked No access to money

Rejected Sent back to customer

Vs.

10

5