Sanctions Compliance Guidance for Instant Payment Systems

Date issued: Sep. 30 2022

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TURBOFAC Commentary (120 words)

Notes:

1) This is the first “Compliance Communiqué” in what may be a series aimed at conveying diligence expectations for operators in certain industries. (Compare the Sanctions Compliance Guidance for the Virtual Currency Industry (2021 Brochure)). “Instant payment systems” appear to include providers such as Venmo and Zelle.

2) The purpose of this document appears to be to provide some guidance on how the vague “risk-based compliance program” expectations found in documents such as A Framework for OFAC Compliance Commitments” translate to the “instant payments” sector in particular. To that end, OFAC signals that it views payments systems involving cross-border transactions as comparatively higher risk, since there is not already a baked-in layer of OFAC sanctions compliance.