During account onboarding, a broker-dealer's automated compliance system alerts the firm to a confirmed match between a prospective international client and the Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list. Under federal sanctions regulations, which action must the member firm take immediately?
- Block (freeze) the client's assets and report the match to OFAC within 10 business days.Answer
- BFile a Currency Transaction Report (CTR) within 15 days of the account opening attempt.
- CReject the wire transfer, return all funds to the originating foreign bank, and close the account.
- DFile a Suspicious Activity Report (SAR) within 30 days while permitting restricted trading.
Answer
Block (freeze) the client's assets and report the match to OFAC within 10 business days.
Under U.S. Treasury regulations administered by OFAC, financial institutions are strictly required to block (freeze) any accounts or property belonging to individuals or entities listed on the Specially Designated Nationals (SDN) list. The firm must report the blocked assets to OFAC within 10 business days of taking action.
Step-by-Step Solution
Key Concept
OFAC Sanctions Compliance and SDN List Asset Blocking Requirements