Answer
No. Effective October 9, 2019, banking institutions subject to U.S. jurisdiction are not permitted to process “U-turn” transactions, i.e., funds transfers originating and terminating outside the United States, where neither the originator nor the beneficiary is a person subject to U.S. jurisdiction. While banking institutions subject to U.S. jurisdiction are no longer authorized to process “U-turn” transactions, they are authorized to reject such transactions, subject to certain conditions (see 31 CFR § 515.584(d)).
Date Released
September 6, 2019