OFAC and the SDN List
Chapters in this video
What this video covers
- What OFAC is, which department houses it, and why its authority flows from executive orders rather than the Bank Secrecy Act
- Who appears on the SDN List and why U.S. persons are prohibited from dealing with anyone on it
- The three mandatory broker-dealer obligations: screen, block (freeze), and report, and the correct order in which they must happen
- Why "block first" is the only acceptable answer on exam day, and why processing the trade then reporting later is always wrong
- The 10-business-day reporting deadline for blocked transactions to OFAC, and why calendar days will be a distractor
- Strict liability for OFAC violations, and why intent, ignorance, or honest mistakes do not shield firms from civil penalties
- How OFAC and the Financial Crimes Enforcement Network (FinCEN) differ in purpose, primary tools, required actions, reporting deadlines, and legal basis
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