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#1894373 - 02/06/14 05:53 PM OFAC updates Foreign Sanctions Evaders List
Xian Ngyuen Offline
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http://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/fse_list_intro.aspx

OFAC announced updates to its Foreign Sanctions Evaders list today. The link above explains a bit more about that list, and leads to other pages where the current list can be viewed or downloaded.

It's important to note that entities on the FSE list *may not* also be listed on the SDN list.

You might have to do a little homework, and check with your list providers.

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#1894429 - 02/06/14 06:44 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
BSAAnonymous Offline
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Does anyone use Lexis Nexis Bridger XG? I just contacted them and they have not made a decision whether or not to add this list.

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#1894786 - 02/07/14 03:18 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
Xian Ngyuen Offline
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Only 5 of the entities on the FSE list are also listed SDNs.

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#1894823 - 02/07/14 03:55 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
NotDoneYet Offline
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WatchDOG Pro is waiting for OFAC to add the new list to their system, hopefully in the next few days.

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#1894837 - 02/07/14 04:05 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
YHWB Offline
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Out there
"E.O. 13608 does not require the blocking of property or interests in property, but persons sanctioned under E.O. 13608 may be persons whose property and interests in property are blocked pursuant to other authorities administered by OFAC. The FSE List entries for persons sanctioned under E.O. 13608 whose property and interests in property are blocked under other authorities include program tags for relevant blocking authorities (e.g., [ISA] or [EO13645]). Such persons are also presented in a segregated sub-section of the FSE List. (Separately, such persons are included on OFACís Specially Designated Nationals and Blocked Persons List with program tags for relevant blocking authorities, as well as for E.O. 13608.)"

So what's the point? What actions are we to take?

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#1894843 - 02/07/14 04:11 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
AUTigers65 Offline
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Did OFAC announce that this was coming and I missed something?

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#1894932 - 02/07/14 05:27 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
Xian Ngyuen Offline
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@YHWB - it's really a question for your own governance group. At a minimum, I would think it means rejecting transactions involving FSE entities that are not also SDNs. Those that are also SDNs are probably already blockable entities.

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#1894947 - 02/07/14 05:39 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
edAudit Offline
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You are here
Originally Posted By: EdSpenser
@YHWB - it's really a question for your own governance group. At a minimum, I would think it means rejecting transactions involving FSE entities that are not also SDNs. Those that are also SDNs are probably already blockable entities.


agreed
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#1894979 - 02/07/14 06:17 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
Islandgirl Offline
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So now I guess we have the SDN List, PLC List & FSE List. Is there any others I am missing?

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#1894981 - 02/07/14 06:29 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
AUTigers65 Offline
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Good news for all of us that use Lexis Nexis Bridger XG! Our rep told us a few moments ago that "the list will be incorporated into the OFAC Non-SDN list in the Bridger environment.....The list will be incorporated as of this afternoon". Kudos to LexisNexis for being on the ball.

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#1894994 - 02/07/14 06:44 PM Re: OFAC updates Foreign Sanctions Evaders List AUTigers65
Islandgirl Offline
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Do they also incorporate the PLC List into the SDN List

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#1895000 - 02/07/14 06:48 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
edAudit Offline
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You are here
Lexis Nexis Bridger XG has more lists than you can imagine it is just a case of "turning on" the ones that you want and "turning off" the others. To the best of my knowledge it would not incorporate (not positive with the new list)but give you an additional warning.
Last edited by EdAudit; 02/07/14 06:49 PM.
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#1895025 - 02/07/14 07:16 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
downbytheriver Offline
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All three credit bureaus also include notifications of possible hits against the OFAC list. Does anyone know if they have plans to include the new FSE list?

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#1895127 - 02/07/14 08:23 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
AUTigers65 Offline
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EUAudit. They did actually end up including these names in an existing (OFAC Non-SDN) watchlist. They've already completed doing so. Impressive quick response though.

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#1895135 - 02/07/14 08:30 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
edAudit Offline
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You are here
That was EdSpenser who review it. However it would not surprise me if they did.
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#1895420 - 02/10/14 05:18 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
MrsSmithCRCM Offline
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Here for the moment
We run the FSE list manually, for now. Is there a prohibition on retaining the list to document compliance? Is anyone else doing this manually? We are a JH -20/20 bank and we manually pull in the OFAC list to run, then get a report of no matches- or listing matches, etc.
I know we are prohibited from retaining the 314(a) list, so we have a cover sheet documenting we searched record #s- XXX, etc. Can I retain this list or is there a similar prohibition from retaining the actual list? It's published and readily available online so it seems to me that we would be able to keep it... thoughts?

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#1895432 - 02/10/14 05:27 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
rlcarey Offline
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Is there a prohibition on retaining the list to document compliance?

Considering it is public information, why would there be a prohibition??
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#1895520 - 02/10/14 07:34 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
MrsSmithCRCM Offline
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Here for the moment
Thanks Randy.

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#1895903 - 02/11/14 05:45 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
Compliance Nut Offline
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So I am confused are we REQUIRED to check against this list?

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#1895936 - 02/11/14 06:17 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
rlcarey Offline
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Nothing. There is no requirement to check anything against this list.
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#1895944 - 02/11/14 06:29 PM Re: OFAC updates Foreign Sanctions Evaders List Compliance Nut
Xian Ngyuen Offline
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Originally Posted By: Compliance Nut
So I am confused are we REQUIRED to check against this list?


Not at all. If you wish to facilitate transactions with people and companies identified by the US Gov't as working to evade US sanctions programs, have at it...

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#1895951 - 02/11/14 06:47 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
rlcarey Offline
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And Ed, you are free to check everything and everybody against the dozens of lists that are out in the ozone. The question was "are you required to do it" and the answer is a flat no.

If the individuals on this list are subject to sanctions that call for the blocking of transaction or the freezing of assets, they will also be found on those lists.

If there was a requirement to check against this list, it would be codified as such.
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#1895959 - 02/11/14 06:53 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
Xian Ngyuen Offline
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Rlcarey,

Sigh. Yes, the answer to "Are we required to..." is "no".
However, the answer to "Should we..." is "Yes".

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#1895972 - 02/11/14 07:05 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
rlcarey Offline
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Ed, thanks for the persistence as you got me doubting myself.

I have to retract what I previously stated as I was going by a summary of the requirements regarding the list.

After a little more research, all transaction with such persons are basically prohibited and they may or may not be listed on the SDN, PLC, etc., lists.

It is probably in the best interests of the banks to include this list within their screening activities.

My apologies.

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#1895982 - 02/11/14 07:17 PM Re: OFAC updates Foreign Sanctions Evaders List Xian Ngyuen
Compliance Nut Offline
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I appreciate the clarifications, I understand the "shoulds" but my President wants to be clear on what is required and what is a risk decision.

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