Podcast
Questions and Answers
What may banks tell customers about blocked funds?
What may banks tell customers about blocked funds?
- That the funds are blocked due to a violation of sanctions regulations
- That the bank is responsible for releasing the funds
- That the bank has blocked funds in accordance with OFAC's instructions (correct)
- That the customer can only contact the bank to seek access to their funds
Who can apply for a license on behalf of a customer in cases of blocked funds?
Who can apply for a license on behalf of a customer in cases of blocked funds?
- The customer
- No one, except in cases of mistaken identity (correct)
- OFAC
- The bank
Can banks provide legal advice to customers regarding OFAC's sanctions regulations?
Can banks provide legal advice to customers regarding OFAC's sanctions regulations?
- Yes, banks can provide legal advice, but only in certain cases
- Yes, banks are required to provide legal advice
- It depends on the type of transaction
- No, banks should not give legal advice to customers (correct)
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Study Notes
Disclosure of Blocked Funds
- Banks are allowed to inform customers that their funds have been blocked in accordance with OFAC's instructions.
- Customers may contact OFAC directly to seek access to their blocked funds.
Bank's Role in License Applications
- Banks do not apply for a license on behalf of the customer or other impacted party, except in cases of mistaken identity.
Bank's Guidance on Sanctions
- Banks may discuss potential transactions with customers to determine if they would violate sanctions.
- Banks should not provide legal advice to customers regarding OFAC's sanctions regulations.
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