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Lesson 55

Secondary Sanctions, OFAC & FATF

OFAC sanctions and FATF standards have different legal and institutional roles. Sanctions programmes can restrict specified dealings and impose conditions; FATF recommendations concern anti-money-laundering and counter-terrorist-financing systems, with risk assessments influencing financial institutions’ checks.
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Sahmino editorial· 30 August· 2 min read· Currency

OFAC sanctions and FATF standards have different legal and institutional roles. Sanctions programmes can restrict specified dealings and impose conditions; FATF recommendations concern anti-money-laundering and counter-terrorist-financing systems, with risk assessments influencing financial institutions’ checks. A FATF statement is not itself an OFAC licence. Secondary-sanctions exposure depends on the applicable authority and conduct, rather than a universal label for every payment. Official lists, notices and authorisations change. Read current texts and dates; the course does not decide a particular transaction’s legal status.

Worked example (hypothetical)

Two payments of the same amount can face different checks because their parties, purpose and jurisdictions differ. Equal size does not make their compliance conditions equivalent.

Check your understanding

Does being outside one list establish permission under every rule? No. Different authorities, programmes and conditions must be considered.

Currency MarketSahmino AcademySecondary Sanctions

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