During a routine onboarding check, a broker-dealer discovers that a prospective customer's name matches an entry on the Specially Designated Nationals and Blocked Persons (SDN) List maintained by the Office of Foreign Assets Control (OFAC). Which of the following actions must the firm take regarding the account and assets?
- Immediately block (freeze) the account assets and report the match to OFAC within 10 business days.Answer
- BAllow normal account operations but file a Suspicious Activity Report (SAR) within 30 calendar days.
- CFile a Currency Transaction Report (CTR) with FinCEN within 15 calendar days if the account holds cash.
- DDecline the account opening request and immediately return all deposited funds to the applicant.
Answer
Immediately block (freeze) the account assets and report the match to OFAC within 10 business days.
When a firm confirms a match against the OFAC Specially Designated Nationals (SDN) List, federal law requires the firm to immediately block (freeze) the customer's account and assets and submit a report to OFAC within 10 business days. Returning the funds or allowing transactions violates U.S. sanctions regulations.
Step-by-Step Solution
Key Concept
OFAC Sanctions Compliance and SDN List Obligations