FinCEN replaces Part 561 List with CAPTA List

OFAC has posted an announcement that it is replacing its List of Foreign Financial Institutions Subject to Part 561 with the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (the “CAPTA List”).

The CAPTA List contains identifying information of foreign financial institutions for which the opening or maintaining of a correspondent account or a payable-through account in the United States is prohibited or is subject to one or more strict conditions. The specific strict conditions or prohibitions to which the foreign financial institutions are subject include the Ukraine Freedom Support Act of 2014, as amended by the Countering America's Adversaries Through Sanctions Act (CAATSA), the North Korea Sanctions Regulations, 31 C.F.R. part 510, the Iranian Financial Sanctions Regulations, 31 C.F.R. Part 561, which were identified on OFAC's now defunct Part 561 List, and the Hizballah International Financing Prevention Act of 2015, which would be identified on the Hizballah Financial Sanctions Regulations List (the “HFSR List”).

The CAPTA List is not part of the Specially Designated Nationals (SDN) List. Information that appears on the CAPTA list will be included in the data formats associated with the Consolidated Sanctions List.