OFAC-issued Regulations and Their Applicable Entities

AC

OFAC (Office of Foreign Assets Control) is an agency of the US Department of the Treasury that administers and enforces economic and trade sanctions based on US foreign policy and national security goals. OFAC-issued regulations apply to a variety of entities, but the answer to this question is B and D.

B. Foreign banks with US customers: OFAC regulations apply to foreign banks that have US customers or conduct transactions in US dollars. This includes banks that maintain correspondent accounts with US banks or clear US dollar transactions through US banks. OFAC regulations require these foreign banks to screen their customers and transactions against OFAC's list of sanctioned individuals and entities. If a customer or transaction matches a sanctioned name or entity, the bank must freeze the funds and report the activity to OFAC.

D. US branches of a foreign bank: OFAC regulations also apply to US branches of foreign banks. These branches are considered US persons under OFAC regulations and are subject to the same sanctions and compliance requirements as US banks.

A. Intermediaries transacting with US banks: While intermediaries transacting with US banks may be subject to OFAC requirements if they are facilitating transactions on behalf of a sanctioned entity, it is not a general rule that OFAC regulations apply to them.

C. Foreign subsidiaries of US banks: Foreign subsidiaries of US banks may be subject to OFAC regulations if they engage in transactions with sanctioned individuals or entities, but it is not a general rule that they are subject to OFAC requirements.

E. Foreign import-export companies: Foreign import-export companies may be subject to OFAC regulations if they engage in transactions with sanctioned individuals or entities, but it is not a general rule that they are subject to OFAC requirements.