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Frequently Asked Questions

Cross-Programmatic Compliance Services Guidance

498. The Compliance Services Guidance states that a U.S. person may solicit information from covered persons and conduct research to make a determination as to the legality of transactions under U.S. sanctions laws. What are examples of research that would be allowable under the Compliance Services Guidance?

U.S. persons may conduct research using the internet, including searches of commercial databases, as well as published reference materials for the purpose of determining the legality of transactions under U.S. sanctions laws. In addition, U.S. persons may solicit information regarding a transaction from covered persons, such as, for example, the currency involved; any involvement of U.S. persons, directly or indirectly; and the identity of the covered person’s counterparty.

January 12, 2017