On 30 September, OFAC issued this guidance which emphasises the importance of taking a risk-based approach to managing sanctions risks in the context of new payment technologies such as instant payment systems and to highlight considerations relevant to managing those risks. This guidance also encourages developers of instant payment systems to incorporate sanctions compliance considerations and features as they develop these systems.
https://home.treasury.gov/system/files/126/instant_payment_systems_compliance_guidance_brochure.pdf
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