OFAC Sanctions Russians and Others
The Department of Treasury’s Office of Foreign Assets Control (OFAC) list of sanctioned persons and entities has grown since Russia invaded Ukraine. But along with Russian oligarchs and entities, OFAC has also designated others, most notably two key Hizballah financiers operating out of Guinea in West Africa, in compliance with Executive Order (E.O.) 13224, prohibiting transactions with terrorists.
OFAC never rests. It adds and sometimes removes persons, entities and countries to sanction lists as necessary per U.S. laws, as in the case of new OFAC sanctions on Russia and others. What does that mean for accounts payable? Simply that you have to keep up.
The addition of Ali Saade and Ibrahim Taher of Guinea to the list might slip by unnoticed while the addition of Putin affiliates Alisher Usmanov, Nikolay Tokarev, Yevgeny Prigozhin and others has been in the headlines. However, OFAC’s list changes. And while it does so “regularly,” it is not on a schedule, and it’s not limited to “headlines!”
Companies must regularly check their vendor (and customer) lists against the sanction lists to comply with U.S. law. And that check has to go two ways. First, of course, a company must run new vendors against the SDN list. But also, a company must check new additions to the SDN list against the company’s existing vendor master because a newly sanctioned entity may already be in a company’s vendor file, having been green-lighted when new to the company.
The sanction lists change and do so irregularly. So, companies must have regular two-way reviews in place to ensure compliance. While some, typically larger organizations, may have the technical capability and time to automate a standard review process, most do not. But service providers can do regular automatic reviews for companies, flagging any apparent matches for the company to follow up.
The company must then determine if the entity is okay. If it is, the company marks it as approved. If it is not, the company must stop any transaction and report it.
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