For reports / suspicions of OFAC / Sanctioned accounts: All cases can go to the AML team for review. Cases can be assigned in ZD to AML_Operations_PY430. If an escalated case that needs to be immediately reviewed, please see #ask-aml_ops Slack channel.
For information on OFAC / SDN individuals and businesses, see here: **OFAC Location Restrictions/U.S Sanctions
***The client flow below mimics the current freelancer flow for OFAC SDN***
All Users with a potential match to the OFAC / SDN list will be required to verify identity information.
This is the only way to properly clear review. Do not recommend any workarounds.
When a “potential match”, IDV will automatically be requested via Au10tix and the OBO IDV Status (not FIVS status) will update.
User will see this (as well as receive an email):
If User reaches out about verification:
Identity Ops is automatically notified for all the below; no tickets need to be submitted to them.
- CS Team does not need to worry about explaining the SDN process to the user, instead, explain and inform that the relevant team will reach out within 24-48 hours before passing the ticket to AML Ops team.
- CS will merge existing tickets to avoid confusion and that tickets could be handled properly. Make sure to check to see if there is already a ticket with AML on this issue. If so, please merge your ticket to that ticket. If there’s no ticket yet, please send your ticket straight to AML.
- Please add a touch response before escalating ticket to AML.
- When a freelancer initiates a disbursement and the name is recognized with a match in the SDN/OFAC list, the transaction will not be processed by the system.
- A silent suspension on the AE will be implemented and future withdrawals will be blocked until the problem is resolved.
- A CSS note will be automatically posted on the user summary.
- Users will automatically go into IDV Process for OFAC / SDN. Once identification is verified and cleared, Identity Ops will re-enable disbursement with a matching CSS Note indicating resumption of the silent suspension on the AE.
- If a client is signaled to go through the review process, they will receive in-product messaging with next steps to follow. They cannot continue with payment processing until this is done and the review is completed.
- Get Started starts the review flow and directs the customer to this flow and the start of the ID verification process. Step by step instructions are given in this flow. If the customer should navigate away from this page they can find it again in their “Settings” - ID Verification. Learn More will take the customer to this help page.