OFAC Policy

Our OFAC policy helps US clients to stay compliant

Payment21® maintains an OFAC policy to meet the legal requirements of its clients. We support our US clients, no matter how small, to stay in compliance with the rules of the Office of Foreign Asset Control (OFAC). US businesses that have foreign customers or suppliers have to strictly comply with all OFAC-related demands. It is imperative that our clients in the US understand the OFAC-programs and sanctions. US businesses are responsible for following OFAC regulations designed to halt terrorist and other illegal funds from circulating.

1. What OFAC compliance means

The US Office of Foreign Assets Control administers and enforces economic sanctions programs primarily against countries and groups of individuals, such as terrorists and narcotics traffickers. The sanctions can be either comprehensive or selective, using asset blockings and trade restrictions to accomplish foreign policy and national security goals. All US persons (which by legal definition include firms) must abide by these sanctions.

2. Who must be in compliance

All US persons must comply with OFAC regulations, including all US citizens and permanent resident aliens regardless of where they are located, all persons and entities within the US, all US incorporated entities and their foreign branches. In the cases of certain programs, such as those regarding Cuba and North Korea, all foreign subsidiaries owned or controlled by US companies also must comply. Certain programs also require foreign persons in possession of US-origin goods to comply.

3. Industry specific information

OFAC provides downloadable guidelines and FAQs for specific industries, including

  • Financial Sector
  • Money Service Businesses
  • Insurance Industry
  • Exporters and Importers
  • Tourism / Travel
  • Credit Reporting
  • Non-Governmental Organizations (NGOs) / Non-profit
  • Corporate Registration

4. OFAC country and list-based sanctions

OFAC country sanctions and list-based sanctions, including general licenses for exceptions; related documents; and laws, rules and regulations authorizing the sanctions are available on the OFAC Sanctions webpage.

    5. Specially Designated Nationals (SDN) List

    OFAC publishes a list of Specially Designated Nationals and blocked persons ("SDN list") which includes over a hundred names of companies and individuals connected with the sanctions targets. A number of the named individuals and 3,500 entities are known to move from country to country and may end up in unexpected locations. US persons are prohibited from dealing with SDNs wherever they are located and all SDN assets are blocked. It is important to check OFAC's website on a regular basis to ensure that your SDN list is current. 

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