My company provides money remittance and account services via the Internet. Does OFAC have any compliance guidance for this type of business?
Complying with United States sanctions policy presents unique challenges to institutions that operate exclusively on the Internet. The Internet has often been thought of as an “anonymous venue” in that e-commerce transactions can be conducted in relative privacy with little or no face-to-face contact among the parties in a transaction. This anonymity creates a significant challenge for Internet businesses that wish to satisfy their due diligence requirements. In order to be compliant with OFAC-governed sanctions regulations, US jurisdiction entities must ensure that they are not: A. Engaging in trade or transaction activities that violate the regulations behind OFAC’s country-based sanctions programs, and; B. Engaging in trade or transaction activities with sanctions targets named on OFAC’s list of Specially Designated Nationals and Blocked Persons (SDN’s). A number of Internet-based financial service companies already developed Internet Protocol (IP) address blocking procedures. These
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- My company provides money remittance and account services via the Internet. Does OFAC have any compliance guidance for this type of business?
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