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Question

Difficulty: MediumAnti-Money Laundering (AML), KYC, and Sanctions Compliance

While conducting routine sanctions screening on an institutional brokerage account, a compliance analyst discovers that an incoming wire transfer originates from an entity newly added to the Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list. Which of the following actions is the broker-dealer required to take under federal sanctions regulations?

  1. Block the transaction immediately, freeze the funds, and report the match to OFAC within 10 business days.Answer
  2. B
    Allow the transaction to settle but file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days.
  3. C
    Reject the wire transfer, return the funds to the originating foreign bank, and file a Currency Transaction Report (CTR) within 15 days.
  4. D
    Notify the customer in writing about the sanction match and grant them 30 days to provide documentation proving non-listed status.

Answer

Block the transaction immediately, freeze the funds, and report the match to OFAC within 10 business days.
Under Office of Foreign Assets Control (OFAC) regulations, when a broker-dealer identifies a transaction involving a Specially Designated National (SDN), it must block (freeze) the transaction and affected assets immediately. The firm must also submit a blocking report to OFAC within 10 business days.

Step-by-Step Solution

1
Identify the applicable regulatory framework for SDN matches.
The Office of Foreign Assets Control (OFAC) enforces economic and trade sanctions against targeted foreign countries, regimes, and named entities/individuals on the SDN list.
Compliance with OFAC regulations is mandatory for all U.S. financial institutions.
2
Determine the mandatory operational protocol for an SDN hit.
When a firm identifies a match on the SDN list, it must immediately block (freeze) the funds/assets so they cannot be accessed or transferred back.
Returning or processing sanctioned funds violates federal sanctions laws.
3
Identify the mandatory reporting requirement and timeline.
The broker-dealer must submit a blocked property report to OFAC within 10 business days of taking the blocking action.
OFAC requires prompt formal disclosure of all blocked assets under federal law.

Key Concept

OFAC Sanctions Compliance and SDN Asset Blocking Requirements
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Topics

Anti-Money Laundering (AML), KYC, and Sanctions Compliance