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CAMS · Question #504

A compliance officer of a financial institution is reviewing a payment for sanctions compliance between two parties in Europe and Asia. The payment is in Euros and involves the provision of services…

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AML/CFT Compliance Programs

Question

A compliance officer of a financial institution is reviewing a payment for sanctions compliance between two parties in Europe and Asia. The payment is in Euros and involves the provision of services to a company located in a jurisdiction subject to Office of Foreign Assets Control secondary sanctions. Which factor is most important in determining the compliance officer's response?

Options

  • AAsset freezes only prohibit US companies from engaging in certain activities with counterparts
  • BA one-off commercial transaction conducted between parties in Europe and Asia is not subject to
  • CThe threat of US sanctions against foreign individuals and entities continues to exist despite the
  • DSecondary sanctions only target specific sectors of the economy such as the banking and finance

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Topics

#OFAC secondary sanctions#extraterritorial jurisdiction#sanctions compliance#cross-border payments
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