Office of Foreign Assets Control (OFAC) Policy

Develop an OFAC policy addressing compliance, including appropriate actions to block, freeze, or prohibit transactions with persons and countries contained on the Specially Designated Nationals (SDN) and Blocked Persons list. Credit unions must take steps to download or otherwise obtain the SDN list from OFAC on a regular basis. Many data processing vendors have incorporated OFAC reviews, including the download of updated SDN lists, in their daily processing and monthly closing routines. Section 314 of the USA Patriot Act addresses cooperative efforts between law enforcement agencies and financial institutions to deter money laundering.

Last updated on March 30, 2026