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Financial Services Law Insights and Observations

OFAC identifies non-U.S. financial institutions on new list of banks facing correspondent account sanctions

Financial Crimes Of Interest to Non-US Persons OFAC Department of Treasury Sanctions

Financial Crimes

On March 14, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the introduction of the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA list). The CAPTA list will identify foreign financial institutions that are prohibited from opening or maintaining correspondent or payable-through accounts in the U.S. pursuant to sanctions including the Countering America's Adversaries Through Sanctions Act, North Korea Sanctions Regulations, Iranian Financial Sanctions Regulations, and the Hizballah International Financing Prevention Act of 2015. Certain regulations have also been amended to reflect the issuance of the new list. OFAC notes that the CAPTA list, which is separate from the Specially Designated Nationals List, will identify the specific prohibitions or strict conditions to which foreign financial institutions are subject. Non-U.S. financial institutions engaging in activity targeted under the above-mentioned regulations risk being added to the CAPTA list.

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