Skip to content
BOL Conferences
Thread Options
#2269706 - 04/27/22 05:32 PM Wire from Russia
Rancher Offline
Member
Joined: Nov 2006
Posts: 75
We have an incoming wire transfer from Russia. There are no OFAC sanctions against the originating entity, the originating bank, or the beneficiary. We are comfortable with the purpose of the wire transfer. Because there are no OFAC sanctions against the originator or the originating bank, is it your understanding that we could process this wire without running into any OFAC issues?

Return to Top
BSA/AML/CIP/OFAC Forum
#2269711 - 04/27/22 06:05 PM Re: Wire from Russia Rancher
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
That would seem to be correct. However, the only place you can get a definitive answer to your question is OFAC itself.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2269716 - 04/27/22 06:21 PM Re: Wire from Russia Rancher
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,796
You are here
While the customer and beneficiary may not be on OFAC. The product sold may, and let's not forget dual use.

https://www.tradecompliance.pitt.ed.../export-commercial-or-dual-use-items-ear
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top

Moderator:  Andy_Z