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ACAMS

CAMS · Question #103

One key aspect of the Office of Foreign Assets Control's extraterritorial reach includes the blocking of certain non-United States initiated transactions for or through the United States (U.S.) for…

The correct answer is A. The transactions are to, or go through, a blocked entity B. Those that are by, or on behalf of, a blocked individual or entity D. Those that are in connection with a transaction in which a blocked individual or entity has an. U.S. law requires that assets and accounts of an OFAC-specified country, entity, or individual be blocked when such property is located in the United States, is held by U.S. individuals or entities, or comes into the possession or control of U.S. individuals or entities. For…

AML/CFT Compliance Programs

Question

One key aspect of the Office of Foreign Assets Control's extraterritorial reach includes the blocking of certain non-United States initiated transactions for or through the United States (U.S.) for benefit of a restricted person or entity. Under which three circumstances are U.S. banks required to block transactions? (Choose three.)

Options

  • AThe transactions are to, or go through, a blocked entity
  • BThose that are by, or on behalf of, a blocked individual or entity
  • CThose that are by or on behalf of a blocked individual and a licensed entity
  • DThose that are in connection with a transaction in which a blocked individual or entity has an
  • EThose that are in connection with a transaction in which a blocked individual or entity has no

How the community answered

(38 responses)
  • A
    76% (29)
  • C
    16% (6)
  • E
    8% (3)

Explanation

U.S. law requires that assets and accounts of an OFAC-specified country, entity, or individual be blocked when such property is located in the United States, is held by U.S. individuals or entities, or comes into the possession or control of U.S. individuals or entities. For example, if a funds transfer comes from offshore and is being routed through a U.S. bank to an offshore bank, and there is an OFAC-designated party to the transaction, it must be blocked. The definition of assets and property is broad and is specifically defined within each sanction program. Assets and property includes anything of direct, indirect, present, future, or contingent value (including all types of bank transactions).

Topics

#OFAC#sanctions blocking#extraterritorial reach#blocked entities

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