ITG FAQ # 2 Answer - Are Tribal Casinos subject to OFAC jurisdiction?

OFAC reporting requirements extend to all persons subject to OFAC jurisdiction, including casinos owned by Federally Recognized Tribes. For blocked and rejected transactions, the casino must send OFAC a corresponding blocking or reject report within 10 days of the action. If the casino blocks any funds, it must also file an annual report of blocked property for each year that it holds those blocked funds. Annual reports are due to OFAC no later than September 30 each year.

 

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