• April 29, 2024

The Only Comprehensive Resource on U.S. Economic Sanctions

OFAC Receives Assistance from Some New Technology

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My apologies for not posting the past few days, I’ve been glued to the internet for the past few days to get the latest on the situation in Iran. It’s really amazing (and sad at the same time) what’s going on over there. What is equally amazing is that it really seems to be becoming the internet revolution, with my sole source of news on the subject coming via the internet from people on the ground. It’s an interesting time to be alive.

In OFAC news, I saw this article today which refers to new technology developed by the Electronic Payments Association that actually
was created as a result of the U.S. Treasury Department’s efforts to align the ACH with its anti-money-laundering efforts. The technology is called IAT and its transactions will be more complicated to handle in part because they’ll be screened against the Specially Designated Nationals (“SDN”) & Blocked Persons list administered by OFAC. As readers of this blog know, the list names individuals and entities banned from financial transactions in the United States because of their links to either a sanctioned country, a sanctioned activity, or some other reason for which OFAC designated them.

This new technology will replace two existing ACH codes for cross-border payments—PBR, for consumer payments, and CBR, for non-consumer transactions.

According to the article, “OFAC estimates that 35 to 40 million transactions each year that originate in other countries but are treated as domestic ACH items likely would be subject to IAT’s rules.”

Smart move. I have always been a fan of the development and implementation of new technologies to carry out OFAC’s regulations. Indeed, I believe that its essential to OFAC’s mission that they work with different entities to develop technologies and strategies that make compliance with their regulations easier. Hopefully the banks can implement it with no major problems.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC litigation. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.

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Erich Ferrari

As the Founder and Principal of Ferrari & Associates, P.C., Mr. Ferrari represents U.S. and foreign corporations, financial institutions, exporters, insurers, as well as private individuals in trade compliance, regulatory licensing matters, and federal investigations and prosecutions. He frequently represents clients before the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), the United States Department of Commerce’s Bureau of Industry and Security (BIS), and in federal courts around the country. With over 12 years of experience in national security law, exports control, and U.S. economic sanctions, he counsels across industry sectors representing parties in a wide range of matters from ensuring compliance to defending against federal prosecutions and pursuing federal appeals.

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