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OFAC/USA Patriot Act Software
Compliance Database
Status Current
Last Update 7/19/2024

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Who must comply?

Who must comply with OFAC?

  All U.S. persons must comply with OFAC regulations, including all U.S. citizens and permanent resident aliens regardless of where they are located, all persons and entities within the United States, all U.S. incorporated entities and their foreign branches. In the cases of certain programs, such as those regarding Cuba and North Korea, all foreign subsidiaries owned or controlled by U.S. companies also must comply. Certain programs also require foreign persons in possession of U.S. origin goods to comply. How much are the fines for violating these regulations? The fines for violations can be substantial. Depending on the program, criminal penalties can include fines ranging from $50,000 to $10,000,000 and imprisonment ranging from 10 to 30 years for willful violations. Depending on the program, civil penalties range from $11,000 to $1,000,000 for each violation.
  All "financial institutions" are required to comply?
Please see the list below
A "financial institution" is defined in the BSA (Bank Secrecy Act) to include:
  • An insured bank (as defined in Section 3(h) of the Federal Deposit Insurance Act);
  • A commercial bank or trust company;
  • A private banker;
  • An agency or branch of a foreign bank in the United States;
  • An insured institution (as defined in section 401(a) of the National Housing Act);
  • A thrift institution;
  • A broker or dealer registered with the Securities and Exchange Commission;
  • A broker or dealer in securities or commodities;
  • An investment banker or investment company;
  • A currency exchange;
  • An issuer, redeemer, or cashier of traveler's checks, checks, money orders, etc.;
  • An operator of a credit card system;
  • An insurance company;
  • A dealer in precious metals, stones, or jewels;
  • A pawnbroker;
  • A loan or finance company;
  • A travel agency;
  • A licensed sender of money;
  • A telegraph company;
  • A business engaged in vehicle sales, including automobile, airplane & boat sales;
  • Persons involved in real estate closings and settlements;
  • The United States Postal Service;
  • A casino, or gaming establishment with annual gaming revenue of $1,000,000;
  • Any business or agency which engages in any activity which the Secretary of the Treasury determines by regulation, to be an activity which is similar to, related to, or a substitute for any activity described in this paragraph; or
  • Any other business designated by the Secretary whose cash transactions have a high degree of usefulness in criminal, tax or regulatory matters.


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