Compliance Center: OFAC Launches Simplified Consolidated Sanctions List

In order to make it easier to comply with OFAC’s sanction regulations, the Office of Foreign Assets Control (OFAC) is now offering all of its non-SDN sanction lists in a consolidated set of data files called the “Consolidated Sanctions List.”

The goal of the consolidation effort is to reduce the number of list-related files that must be downloaded in order to maintain an automated sanctions screening program.  If OFAC creates a new sanctions list where the action required of a U.S. person does not necessarily entail blocking, the office will add the new data associated with that list to the files if appropriate.

The lists include:

  • Non-SDN Palestinian Legislative Council List (NS-PLC);
  • Part 561 List;
  • Non-SDN Iran Sanctions Action List (NS-ISA);
  • Foreign Sanctions Evaders List (FSE); and
  • Sectoral Sanctions Identifications List (SSI).

In approximately 6 months, OFAC will cease issuing independent data files for the FSE List, the SSI List, and the NS-PLC List.  During the transition period, OFAC will produce these data on both the Consolidated Sanctions List and on the appropriate individual lists.

OFAC has upgraded it Sanctions List Search tool to provide users the ability to search for a name on the SDN List, on the Consolidated List, or on both lists simultaneously.

Compliance Question of the Week

If a married couple gets a divorce and the outstanding joint loan balance goes delinquent, can the credit union collect against either ex-spouse, or just against the one that the court assigned responsibility for the loan?

The credit union can collect against either ex-spouse.  The division of debt in the divorce decree affects on the ex-spouses, not creditors. When the court assigns responsibility for a loan to one ex-spouse, a contract is being created between the parties to the marriage. In this case, if the credit union collected from the ex-spouse who was not assigned responsibility by the court, that ex-spouse could begin an action against the other ex-spouse for violation of the court order.

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National Credit Union Administration (NCUA)

The NCUA, jointly with other federal agencies, released a proposed flood insurance rule. Comments will be due 60 days after the proposed rule is published in the Federal Register.

The NCUA released their Board Action Bulletin detailing the outcome of their most recent board meeting.

The NCUA released its October edition of the NCUA Report.

Consumer Financial Protection Bureau (CFPB)

The CFPB announced that they have finalized the mortgage rule amendments that they initially proposed in April 2014. The finalized rule is aimed at helping ensure consumers’ access to credit.

Financial Crimes Enforcement Network (FinCEN)

FinCEN released its quarterly SAR report.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of October 21, 2014. The last update prior to this was October 16, 2014.

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted in Compliance, NCUA.