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Question 141/263

A non-US bank is implementing a sanctions compliance program. Which extraterritorial reach of Office of Foreign Assets Control (OFAC) regulations would matter the most to the foreign bank?

A. OFAC administers sanctions based on criminal investigations against targeted foreign individuals.

B. OFAC sanctions programs prohibit transactions and require the blocking of assets of foreign individuals that appear in negative media sources.

C. OFAC acts only under presidential wartime emergency powers, against countries and foreign individuals considered enemies of the US.

D. OFAC has the power to impose significant penalties on foreign individuals who are found to be in violation of the blocking orders.

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Question 141/263

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