31 CFR § 515.314 - Banking institution.

Date issued: Jul. 09 1963

TURBOFAC Commentary (133 words)

Notes:

1) Provision unique to the CACR. The typical sanctions regulation defines "U.S. financial institution," distinguishing between branches and subsidiaries, but for the purposes of the CACR, the distinction is not meaningful as both are considered a "Person subject to the jurisdiction of the United States" ("515.329"). Note that while the definition of "financial institution" in the typical sanctions regulation appears broader than "banking institution" for the purpose of the CACR may appear narrower than that of the definition of "financial institution" in the typical modern sanctions program, but it is unlikely that OFAC would interpret it as such.

2) See Case No. CU-2019-361318-1 for OFAC appearing to regard the New York Office of the State Comptroller abandoned funds office as being a “banking institution” for purposes of this provision.