While Argentine and Chilean banks are not directly subject to OFAC jurisdiction, most maintain correspondent banking relationships with U.S. financial institutions. These relationships create de facto compliance obligations, as processing dollar-denominated transactions or transfers touching the U.S. financial system triggers OFAC regulations. Major Latin American banks routinely screen customers against the SDN List and often apply U.S. sanctions standards voluntarily to preserve correspondent access. Designated individuals frequently find accounts frozen or closed even for purely domestic peso or Chilean peso transactions, as institutions implement risk-averse overcompliance policies.
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