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The new OFAC regulations are not limited to banks. Insurance companies, securities and
investment firms, and import/export trading companies are also subject to OFAC Rules.
More specifically, Section 352 amends the definition of a financial institute to now include:
- An insured bank (as defined in section 3(h) of the Federal Deposit Insurance Act)
- A commercial bank or trust company
- An agency or branch of a foreign bank in the United States
- A private banker
- A broker or dealer in securities or commodities
- A thrift institution
- A broker or dealer registered with the Securities and Exchange Commission under the Securities and Exchange Act of 1934
- An uninsured institution (as defined in section 401(a) of the National Housing Act)
- An investment banker or investment company
- A currency exchange
- An issuer, redeemer, or cashier of travelers' cheques, money orders, or similar instruments
- A dealer in precious metals, stones, or jewels
- A loan or finance company
- A pawnbroker
- A travel agency
- An operator of a credit card system
- A licensed sender of money
- A telegraph company
- A business engaged in vehicle sales, including automobile, airplane, and boat sales
- Persons involved in real estate closings and settlements
- The United States Postal Service
- An agency of the United States Government.
OFAC acts under presidential wartime and national emergency powers, as well as authority
granted by specific legislation, to impose controls on transactions and freeze foreign assets
under U.S. jurisdiction.
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