After the September 11, 2001, terrorist attack, the President issued an Executive Order requiring all financial institutions to immediately block any assets held in the names of individuals or organizations identified as being associated with a terrorist group and to immediately notify the Office of Foreign Assets Control. The number of “Specially Designated Nationals” on the list has increased significantly since the Executive Order was issued. These names, including aliases, have been distributed to you through our Regulatory Alerts issued in September, October, and November.
Although the terrorist attacks have brought attention and urgency to this effort, credit unions have had the responsibility for identifying and blocking assets and transactions from a number of countries, and individuals from those countries, for a number of years. OFAC is responsible for administering sanctions under eight statutes, in addition to the recent Executive Order. OFAC has issued sanctions against individuals and entities in thirteen countries. The listing of blocked entities, which is 61 pages of fine print, can be found at OFAC’s web site at: http://www.treas.gov/ofac. Federally insured credit unions are required to enforce these sanctions and should maintain a current list of these prohibited individuals and countries, and compare their members, new members, and account transactions against the list, blocking all accounts and transactions with the prohibited entities.
As part of NCUA’s responsibility to ensure federally insured credit unions comply with applicable laws and regulations, we have developed the attached checklist which an examiner may use in documenting the review of the credit union’s compliance with the OFAC regulations. I am providing this checklist to you for your information.