The President issued an Executive Order, dated September 2001, targeting terrorists and included the Office of Foreign Asset Control’s (OFAC) Specially Designated Nationals List (SDN). That list and a follow up list, which added the names of additional terrorists, were sent to all federally insured credit unions in Regulatory Alert No: 01-RA-10 and Regulatory Alert No: 01-RA-12. On November 2, 2001, OFAC issued a third Bulletin (attached), which states that all Foreign Terrorist Organizations (FTOs) have now also been designated Specially Designated Global Terrorists (SDGTs). The attached Bulletin shows the affected entries. On November 7, 2001, OFAC issued a fourth Bulletin (attached), which added a significant number of terrorist organizations and individuals to its SDN list. On December 3, 2001, OFAC issued a fifth Bulletin (attached), which added two new terrorist organizations. On December 4, 2001, OFAC issued a sixth Bulletin (attached), which added three new terrorist organizations.
The assets of all SDGT’s listed on the four bulletins must be blocked and immediate notice must be given to OFAC. Credit unions should call OFAC’s hotline at 1-800- 540-6322 if they have any questions.
The Executive Order requires immediate notification of OFAC when a financial institution identifies potential or actual assets of any of the listed entities. If verified by OFAC as a blockable transaction/asset, a blocking report must be faxed immediately to OFAC. Credit unions should call OFAC’s hotline to report any hits. For further information and details see OFAC’s web periodically at: www.treas.gov/ofac (opens new window). For questions, call OFAC compliance at 1-800-540-6322.
All of OFAC’s SDN material has been revised due to the changes in the latest Bulletins. Credit unions are advised to check OFAC’s web site daily for updated notices. Credit unions that do not have access to the Internet can call OFAC’s hotline, or respective NCUA regional office or state supervisory authority. In addition, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has established a FINANCIAL INSTITUTIONS HOTLINE, 1-866-556- 3974, for financial institutions to voluntarily report to law enforcement authorities suspicious transactions that may relate to recent terrorist activity against the United States. For further information see FinCEN’s web site at: http://www.treas.gov/fincen.