When sanctions screening identifies a match, you must either block or reject the transaction. The difference matters.
| Action | When | What happens | Reporting |
|---|---|---|---|
| Block | SDN property or sanctioned jurisdiction | Funds frozen in blocked account | 10 business days |
| Reject | Cannot process, no blocked property | Funds returned to sender | 10 business days |
Transaction involves SDN-listed person or comprehensively sanctioned jurisdiction (Iran, North Korea, Syria, Cuba, Crimea). Funds placed in blocked interest-bearing account.
Step 1: Freeze funds immediately. Step 2: Notify customer (without SAR tipping off). Step 3: File OFAC blocking report within 10 business days. Step 4: File annual report by September 30. Step 5: Maintain records 5 years.
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
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