Wire from Russia

Posted By: Rancher

Wire from Russia - 04/27/22 05:32 PM

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?
Posted By: John Burnett

Re: Wire from Russia - 04/27/22 06:05 PM

That would seem to be correct. However, the only place you can get a definitive answer to your question is OFAC itself.
Posted By: edAudit

Re: Wire from Russia - 04/27/22 06:21 PM

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