Câu 6: CGSS: Certified Global Sanctions Specialist

When conducting high-risk reviews of its Russian Oligarch client list, a US financial institution (FI) discovers that a non-blocked entity has an executive sanctioned under OFAC who has been signing contracts on behalf of a company. What is the legal position?

1. A. The FI may process transactions when the blocked individual is acting on behalf of the non-blocked entity, but negotiations and signing contracts are unlawful.
2. B. An OFAC license is not required because the sanctioned individual is an executive and has no ownership, so the activity is permissible.
3. C. Unless the non-blocked entity has prior authority from OFAC, this type of activity is prohibited. — đáp án hiện tại
4. D. Provided the sanctioned individual does not own 50% or more of the non-blocked entity, signing contracts for non-blocked entities is permissible.