Would anyone be willing to share some information on how your financial institution goes about monitoring the accounts of individuals (such as international exchange students) for citizens of countries with very specific OFAC sanctions & restrictions? For example, accounts for citizens of Burma or Iran for which OFAC allows a bank to open such accounts - but the bank must do things such as ensure that the customer doesn't conduct transactions for commercial businesses, move back to the country and conduct all of their activity there, etc. The challenge is how to always be aware of everything that your customer is doing or might do in the future, at all times. Perhaps your bank just chooses not to do business with individuals from such high risk/OFAC sanctioned countries at all? Although, making such a blanket determination carries its own (perhaps reputational) level of risk.

Because we don't have any effective means of administering accounts for residents of the countries you've mentioned, we will not bank them.

Our stance is that the nature of the OFAC sanctions, particularly those for Iran, where our ability to operate the account depends on where in the world the customer happens to be at the time of transaction, presents too much risk for a violation to occur. I'm not sure how we would be able to mitigate the risks, short of requiring the customer to wear an an ankle bracelet with a GPS unit...

We do not open accounts for a permanent resident of a sanctioned country. If they are immigrants of that country we have a list of documentation required to be received from the person. If they have this documentation we send it to our AML risk department to review and determine if the account will be opened.