On March 14, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced the creation of a new list specifically sanctioning foreign financial institutions (FFIs). Notably, the Correspondent Account of Payable-Through Account Sanctions (the CAPTA List) identifies FFIs that are prohibited or severely restricted from opening or maintaining a US correspondent account. US financial institutions that provide US dollar-clearing services for foreign banks should pay close attention to the new list, as FFIs will be subject to heightened scrutiny and could face additional consequences for engaging with sanctioned countries and parties. For more information about the FFI list, read this post on the Anticorruption Blog.

This post is an excerpt of our US-EU: Export Controls and Sanctions Update, January – March 2019.