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Return Wire when Originator is not on SDN?

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Question: 
Shall we return a wire sent from Russia when the originator is not on SDN but the originator's bank, SBERBANK is on the e Sectoral Sanctions Identifications List?
Answer: 

"SBERBANK" appears hundreds of times on OFAC's Sectoral Sanctions Identifications list. To know exactly whether you should return the wire, you should contact OFAC directly for a determination. If you are unable to do that, I would recommend refusing the wire.

First published on 11/07/2021

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