I want to see if anyone can give me some guidance on OFAC in relation to trade finance / letters of credit.

We keep having the same discussion with our trade finance dept. concerning discounted letters of credit and what parties to OFAC at what time. BSA dept thinks that until the transaction is closed, all parties related to the original transaction are still involved even if the letter of credit was discounted and the beneficary was paid.

Our trade area says once the letter of credit is discounted, the customers are no longer involved in the transaction and now it is strictly between the banks involved until the maturity date.

If there are others that do letters of crdit, please share how you do it.

Thanks