Απάντηση στο: Εύρεση πελάτη σε SDN List του OFAC

[joanna-k]

YOu need to consider US elements in the potential transaction – if payment is in USD or in different way will touch US bank (or bank applying OFAC sanctions at group level – eg. foreign subsidiaries or affiliates of banks with strong US presence), the US bank will be required to freeze funds.
If there are no US elements in the transaction and correspondent bank (SEPA payment) – than from sanctions compliance and legal perspective such payment could be done but in practice, in my view you should first approach the receiving bank and ask if they will accept the payment, as they might consider processing of such payment as gap in your sanctions screening process and start enquiries. You shall consider the amounts that are to be transferred and profile of your customer (what is the reason that he/she is on a sanctions list). In practice, for such payments many times there are direct communications between compliance departments and in certain cases OFAC approvals (despite the fact that technically not required).
Hope this helps somehow.