What should a bank do when it receives a request from a customer to transfer funds to an individual in Iraq?
What should a bank do when it receives a request from a customer to transfer funds to an individual in Iraq?
When a bank receives a request to transfer funds to an individual in Iraq, the safest action is to block the transfer. Iraq is a country subject to U.S. sanctions, and conducting due diligence might not be sufficient to ensure full compliance with the Office of Foreign Assets Control (OFAC) regulations. Blocking the transfer avoids potential legal violations and ensures that no funds are inadvertently transferred to sanctioned individuals or entities.
When a bank receives a request from a customer to transfer funds to an individual in a sanctioned country like Iraq, it should conduct appropriate due diligence. If neither the individual nor the financial institution involved in the transfer is listed on the Specially Designated Nationals (SDN) list maintained by the Office of Foreign Assets Control (OFAC), the bank can typically proceed with the transfer. However, if either the individual or the financial institution is on the SDN list, the bank should block the transfer and report it to OFAC. Option B reflects the standard practice of checking the SDN list before processing such transactions to ensure compliance with sanctions regulations.