Our customer used Paypal to buy something from Bulgaria. We received a Sanctioned Country hit on our IAT list. I tried to read up on all of this but I'm still confused. I used the OFAC site and we do not get a hit on the merchant in Bulgaria. I read the Balkans sanction on the site also. I'm still confused if we must reject the transaction or not. I am thinking no because we do not have a positive SDN list hit??

The Balkans is a region, not a country. Bulgaria is not an OFAC sanctioned jurisdiction. Could there be sanctioned parties within Bulgaria? Yes. But the country itself is not subject to any OFAC sanctions.

Regarding your hit. Are you sure it's related to OFAC's SDN List and not some additional list?

This link may be helpful as well.

http://www.bankersonline.com/ofac/ofacchart.html

This thread discusses which countries are within the Balkans region. Bulgaria is one of the ones listed.

http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1669010

The sanctions state...

"the former Yugoslav Republic of Macedonia, in southern Serbia, the Federal Republic of Yugoslavia, and elsewhere in the Western Balkans region,"

Bulgaria is on the eastern side of the region. FWIW the State Department does not consider Bulgaria as part of the Balkans on their website.

http://www.state.gov/p/eur/rt/balkans/

Unless I'm not following, there is no debate about whether the Balkans region is sanctioned by OFAC or if Bulgaria is included in the Balkans. But, as I understand it, Bulgaria itself isn't sanctioned. It's not the equivalent of Iran today or Cuba 10 years ago. It is permissible to process wires for Bulgaria assuming that the originator or beneficiary is not a sanctioned party.

I'd be curious if any one has a different opinion and what they are basing it on.

Agreed. 100%.

Same here.