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(Money laundering and terrorist financing have a number of features in…

- - - - The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury administers and enforces economic and trade sanctions based on the US foreign policy and national security goals against targeted foreign countries and regimes; terrorists; international narcotics traffickers (under the ‘Kingpin’ Sanctions Regulations); and those engaged in activities related to the proliferation of weapons of mass destruction; and other threats to national security, foreign policy or the economy of the US.
      - It is important to note that while US sanctions do not directly apply to non-US firms outside the US, the use of the US dollar currency automatically engages OFAC regulations. US prosecutors take the view that if a financial transaction has cleared in the US (as do all US dollar payments, in New York), the US has jurisdiction over the offence.
      - OFAC publishes a list of ‘specially designated nationals‘ or SDNs (known as the SDN List) whose assets are blocked and firms, including US persons, are generally prohibited from doing business with them.
    - - Many local jurisdictions also have their own sanctions requirements; examples in the US and UK.
    - - The USA PATRIOT (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism) Act contains provisions that require financial sector businesses to deny terrorists access to financial systems. This act has worldwide implications for anybody transacting in US dollars.
      - The US Treasury Financial Crimes Enforcement Network (FinCEN) enforces Special Measures, which restrict the access of these persons to the US financial system.
    - - In the UK, the Foreign and Commonwealth Office (FCO) is responsible for the overall policy of sanctions, and the scope and content of the international regimes.
      - HM Treasury is responsible for the implementation and administration of international financial sanctions in the UK; domestic designation; licensing exemptions to financial sanctions; and maintaining lists of parties subject to sanctions.
      - HM Treasury may add a name to its sanctions list that might not appear on the equivalent UN or EU lists owing to designations under the:Terrorism (United Nations Measures) Order 2006, and Al-Qaeda and Taliban (United Nations Measures) Order 2006.