On Friday, we had a customer attempt to send a wire to Myanmar. The beneficiary of the transaction does not appear to be on the SDN List. We did not process the wire, but have collected the funds and moved them to an account at this time. My question is with the sanctions on Burma, does this require us to block and hold the funds in an interest bearing account, or reject the wire and return the funds to the customer? Also, this would be the first time that I have had to do this with sending to an OFAC sanctioned country, so I am wanting to make sure I do everything in compliance, do I fill out the form (blocked or rejected) and email that to the US Treasury Department as well? Thank you for your help!

My understanding is Myanmar is subject to comprehensive sanctions which is usually a blockable event. That said it really does depend on the details of the wire. I think you're following the right path. If you call the OFAC hotline they will usually get back to you quickly for an in process funds transfer.

I would hold the funds until this is resolved. If it's blockable you have the funds. If it turns out that it's a prohibited transaction you can then return the funds to the client. I believe you have to notify OFAC either way.

Thank you very much!! I have reached out to the email for questions to see what they say. If I don't get a response today, I will give them a call and see if they can respond

You can also check with the customer to find if they have a license for the transaction. (while unlikely it is possible)

https://home.treasury.gov/policy-is...s-programs-and-country-information/burma