The Clearing House Association in coordination with ABA, IIB, and SIFMA submitted a letter to OFAC regarding the Ukraine-Related Sectoral Sanctions. The letter highlights the core compliance challenges that the sanctions present to the industry and suggests ways to address those challenges, including by OFAC’s (i) issuance of guidance recognizing that controls at the initiation of transactions and due diligence on direct customers should be the primary focus of compliance efforts and (ii) extension of FAQ #116 to sectoral sanctions identifications.
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