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However, for retail transactions there may be concerns associated with housing mortgage finance and potentially certain investment options that may involve controversial or high-risk projects/companies.

Basic desktop review procedures should be applied to identify the rare cases in which there may be concerns with corporate accounts that are linked to companies or individuals whose activities are viewed as harmful, including arms manufacturing, money laundry, and terrorism, which may represent a legal and reputational risk to the financial institution.

The financial institution’s procedures should include checking against a list of excluded activities and automatically checking international databases to identify companies or individuals suspected of money laundry and/or terrorism.

Resources:

Office of Foreign Asset Control (U.S. Department of Treasury)


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