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#1202332 - 06/17/09 02:07 PM OFAC Coutry Santions
ksm Offline
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ksm
Joined: May 2003
Posts: 302
Midwest
Does any one have an updated list identifying which OFAC countries are restricted and which Countries are list based? Ex. North Korea is restricted. Iran is list based. Our ATM vendor is going to charge us $250/country we want to block ATM activity. I am thinking about blocking the restricted countries and allowing for list based counties. What do other institutions do? Do other institutions pay to have this activity blocked? I think the vendor should provide this free of charge since it is a legal requirement.

Thanks for your response.

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#1202513 - 06/17/09 03:41 PM Re: OFAC Coutry Santions ksm
gofer Offline
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Joined: Nov 2005
Posts: 85
The OFAC webpage is a good place to start. However, in order to understand the various country sanctions that are out there, you need to read through each of the country programs. It isn't immediately evident whether a particular program covers broad sanctions on activity with a particular country or is list-based (i.e., those that only apply to certain individuals/entities that are named on OFAC's SDN list).
http://www.ustreas.gov/offices/enforcement/ofac/

Bankers Online also maintains an OFAC Sanctions Matrix that provides summary information for the various country sanctions programs.

Incidentally, please note that sanctions against Iran are not list-based -- in fact, they are extremely restrictive and can have effects on all types of transactions that touch Iran (but do not involve any SDNs).

Good luck with getting a vendor to perform any services for free. However, assuming your ATM vendor is a U.S. entity, they should have their own concerns about facilitating transactions with sanctioned countries, as potential exposure to OFAC violations is not unique to financial institutions.

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#1202519 - 06/17/09 03:45 PM Re: OFAC Coutry Santions ksm
cbinder63 Offline

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cbinder63
Joined: Dec 2001
Posts: 674
Colorado
Bankers Online has this handy matrix:

OFAC Chart
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Opinions expressed are my own.

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#1202911 - 06/17/09 07:41 PM Re: OFAC Coutry Santions cbinder63
ksm Offline
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ksm
Joined: May 2003
Posts: 302
Midwest
Original poster - I meant to say Iraq list based. Sorry for any confusion.

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#1202938 - 06/17/09 08:07 PM Re: OFAC Coutry Santions ksm
Hrothgar Geiger Offline
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Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
I want to amplify gofer's point. A US ATM operator would be prohibited from allowing access from Cuba, for example, or Iran. I would think they should be marketing their compliance to US law to you as a selling point for their network, instead of charging you to make themselves compliant. Just my US$.02, unadjusted for recent forex speculation.

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#1203089 - 06/17/09 10:24 PM Re: OFAC Coutry Santions Hrothgar Geiger
SunnyT Offline
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SunnyT
Joined: Feb 2008
Posts: 1,362
Sandy Beach - Florida
My confusion is always exactly which countries do they include in the "Balkens".
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#1203112 - 06/18/09 12:00 AM Re: OFAC Coutry Santions SunnyT
Hrothgar Geiger Offline
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Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
I know. I always have to re-read the program.

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