Material Truth Regarding Transactions for U.S. Sanctions Laws

B

To understand this question, it is important to have a basic understanding of United States (U.S.) sanctions laws and their jurisdiction.

U.S. sanctions laws are implemented by the U.S. government to prohibit certain transactions with individuals, entities, and countries that are deemed a threat to U.S. national security, foreign policy, or economic interests. These sanctions laws can have extraterritorial jurisdiction, meaning that they can apply to transactions that take place outside of the U.S. but involve U.S. persons or have a connection to the U.S.

Based on this background, let's review each of the answer choices to determine which one is correct.

A. Transactions are traced to illegal proceeds This answer choice is incorrect. While transactions involving illegal proceeds can be subject to U.S. sanctions laws, this is not a requirement for such laws to have jurisdiction.

B. Transactions are processed by a U.S. person This answer choice is partially correct. Transactions processed by a U.S. person can be subject to U.S. sanctions laws. However, this is not the only factor that determines jurisdiction.

C. Transactions are stripped of beneficial owner information This answer choice is incorrect. Transactions that are stripped of beneficial owner information may be a red flag for potential money laundering, but this does not necessarily trigger U.S. sanctions jurisdiction.

D. Transactions are identified as proceeds of foreign corruption This answer choice is incorrect. Transactions that involve foreign corruption can be subject to other U.S. laws, such as the Foreign Corrupt Practices Act (FCPA), but this does not automatically give rise to U.S. sanctions jurisdiction.

Based on the above analysis, the correct answer is B. Transactions processed by a U.S. person can be subject to U.S. sanctions laws, but it is important to note that this is not the only factor that determines jurisdiction. Other factors, such as the involvement of sanctioned parties, the nature of the transaction, and its connection to U.S. interests, can also trigger U.S. sanctions jurisdiction.