“As a compliance supervisor, I can say that Visual OFAC has been a fantastic tool for our company. No longer having to manually screen these massive compliance lists has made our lives so much easier. A lot of stress and worry leaves you because you feel certain that you’re safe on all your transactions.”
COMPLIANCE SUPERVISOR, MANUFACTURER, LEXINGTON, KY
The U.S. Treasury’s Terrorism and Financial Intelligence Office (TFI) develops and implements U.S. government strategies to combat terrorist financing domestically and internationally, develops and implements the National Money Laundering Strategy, as well as other policies and programs to fight financial crimes. In marshaling the department’s intelligence and enforcement functions, TFI has the twin aims of safeguarding the financial system against illicit use and combating rogue nations, terrorist facilitators, weapons of mass destruction (WMD) proliferators, money launderers, drug kingpins, and other national security threats. These individuals are referred to as Specially Designated Nationals, or SDNs, and by doing business with them, you may be breaking the law. This is why screening against OFAC’s watch lists is so critical.
Designating Specially Designated Nationals (SDN)
Designations are an important resource in TFI’s prosecution of the war on financial terror. With them, TFI is able to freeze the assets of individuals and groups who seek out to commit terrorist acts, as well as those entities who attempt to support them. When examining individuals or organizations for potential designation, the United States works in conjunction with authorities from several other nations, and with international organizations, such as the European Union and the United Nations.
One of the primary designation tools available to TFI is Executive Order 13224 (E.O. 13224), which was signed by the president on September 23, 2001. Under E.O. 13224, individuals and entities can be designated as a Specially Designated National if they meet one of five sets of criteria, summarized below:
- foreign individuals or entities listed in the Annex to E.O. 13224 (E.O. 13224, 1(a));
- foreign individuals or entities that “have committed or pose a significant risk of committing acts of terrorism that threaten the security of U.S. nationals or the national security, foreign policy, or economy” of the United States (E.O. 13224, 1(b));
- individuals or entities that either are “owned or controlled by” or “act for or on behalf of” those parties already designated under sub-sections 1(a), 1(b), 1(c), or 1(d)(i) of E.O. 13224 (E.O. 13224, 1(c));
- individuals or entities that “assist in, sponsor, or provide financial, material, or technological support for, or financial or other services to or in support of” such acts of terrorism or those parties already designated under E.O. 13224 (E.O. 13224, 1(d)(i));
- individuals or entities that are “otherwise associated” with those parties already designated under sub-sections 1(a), 1(b), 1(c), or 1(d)(i), of E.O. 13224 (E.O. 1 3224, 1(d)(ii)).