Which statement is the most accurate in describing who must comply with Office of Foreign Assets Control (OFAC) sanctions?
Correct Answer: A
OFAC sanctions apply extraterritorially, meaning U.S. persons must comply regardless of their location.
Option A (Correct): OFAC sanctions apply to all U.S. citizens, permanent residents, entities incorporated in the U.S. (including foreign branches), and individuals/entities within U.S. jurisdiction.
Option B (Incorrect): Foreign branches of U.S.-incorporated entities must comply with OFAC sanctions.
Option C (Incorrect): OFAC sanctions apply to all U.S. citizens, including dual nationals.
Option D (Incorrect): U.S. citizens and permanent residents must comply with OFAC sanctions even when located abroad.
Best Practices for OFAC Compliance:
Screen all transactions against the Specially Designated Nationals (SDN) list.
Ensure compliance programs extend to foreign branches and subsidiaries.
Monitor international business activities for potential sanctions violations.
Reference:
OFAC Sanctions Guidelines (U.S. Treasury Department)
FATF Recommendation 7 (Targeted Financial Sanctions Compliance)