National framework

Office of Foreign Assets Control (OFAC)

The US sanctions authority — administers the Specially Designated Nationals list, country programmes and sectoral sanctions with extraterritorial effect.

What it is

OFAC is the bureau of the US Treasury that administers and enforces US economic and trade sanctions — country-based programmes (Russia, Iran, North Korea, etc.), list-based programmes (the Specially Designated Nationals (SDN) list), and sectoral sanctions. Its rules have extraterritorial reach: any USD transaction, any dollar-clearing relationship, any US-person involvement triggers OFAC jurisdiction, even between non-US parties.

Why every European bank has to know it

EU sanctions and OFAC sanctions overlap but are not identical. A European bank screening payments needs to test against both EU/UN/national lists and the OFAC SDN list because USD clearing in particular passes through US correspondent infrastructure. The 2014 BNP Paribas case (USD 8.9 bn fine) and successor enforcement actions made OFAC compliance a board-level topic for European banks regardless of EU-only branding.

See also

Authoritative sources

How this matters in our work

Bucephalus sanctions screening runs against EU/UN/OFAC lists in parallel, with fuzzy and phonetic matching tuned for the transliteration patterns typical of OFAC's high-priority programmes.