The Office of Foreign Assets Control and the SDN List

Question: What do the following have in common — Advanced Electronics Development, American Air Ways Charters, Inc., Atlas Equipment Company Ltd., Global Relief Foundation Inc., Public Corporation for Building and Construction, Reeves-Taylor, Red Eagle Group, T N K Fabrics Limited, Technic Digimex Corp, and Viacon International, Inc.?

Answer: All are found on the Specially Designated Nationals and Blocked Persons (SDN) list of the Office of Foreign Assets Control or OFAC.

Introduction

It is illegal for U.S. businesses to trade with certain individuals, organizations, and countries, as designated by the United States government. The Department of the Treasury’s Office of Foreign Assets Control (OFAC) publishes a list identifying many of those designated entities. These not only include countries like North Korea and Cuba but also such persons and entities as terrorists, narcotics traffickers, weapons traffickers, certain diamond traders, and their organizations. U.S. persons who violate these U.S. sanctions incur civil or criminal penalties.

However, many organizations outside of financial services are unaware of OFAC and of their obligations and liabilities with regard to dealing with designated persons or entities. (It is also illegal to launder money, but anti-money laundering ...

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