Extract to table

When a transaction involves a blocked person or property, BRB is required to block the transaction and file a blocking report with OFAC within ten (10) business days

When a transaction involves a prohibited activity that does not require blocking, BRB is required to reject the transaction and maintain records of the rejection

However, we must candidly acknowledge factors that could push the analysis toward a more serious posture

BRB must approach the OFAC enforcement risk as a separate and independent exposure that requires its own strategic response

Until those results are available, the analysis must necessarily proceed on the basis of scenarios reflecting different possible outcomes

The VSD filing, while directed to OFAC, also serves a defensive purpose in the DOJ context: a demonstrated pattern of proactive disclosure, cooperation, and remediation is inconsistent with the willfulness and intent elements that DOJ must prove in a criminal sanctions prosecution