D-day Game Unblocked
Jesper Sahu
Once it has been determined that funds need to be blocked, they must be placed into an interest-bearing account on your books from which only OFAC-authorized debits may be made. The blocking also must be reported to OFAC Compliance within 10 business days. Some banks have opted to open separate accounts for each blocked transaction, while others have opted for omnibus accounts titled, for example, "Blocked Libyan Funds." Either method is satisfactory, so long as there is an audit trail which will allow specific funds to be unblocked with interest at any point in the future.
Generally yes. In most cases (excluding Iraq, for instance) OFAC regulations contain provisions to allow a bank to debit blocked accounts for normal service charges, which are described in each set of regulations. The charges must be in accordance with a published rate schedule for the type of account in which the funds are maintained.
No. OFAC regulations are tailored to further the requirements and purposes of specific Executive Orders or statutes which provide the basic outline of each program. In some cases, the President has determined that a comprehensive asset freeze is appropriate, and in others the President has determined that more limited restrictions (for example, import bans) are in order. The individual program web pages outline the restrictions for each program. Special attention should be given when reviewing sanctions list targets that are included on one of OFAC's non-Specially Designated Nationals sanctions lists.
In some cases, an underlying transaction may be prohibited, but there is no blockable interest (i.e., that of a Specially Designated National (SDN) or blocked person or government) in the transaction. In these cases, the transaction is simply rejected, or not processed and returned to the originator.
For example, a U.S. financial institution would have to reject a wire transfer between two third-country companies (non-SDNs) involving an export to a company in Iran that is not otherwise subject to sanctions. Since there is no interest of the blocked person (e.g., the Government of Iran, and Iranian financial institution, or an SDN), there is no blockable interest in the funds. However, the U.S. financial institution cannot process the transaction because that would constitute a prohibited export of services to Iran pursuant to the Iranian Transactions and Sanctions Regulations (ITSR), unless authorized by OFAC or exempt from regulation. Similarly, a U.S. financial institution is prohibited under the ITSR from an engaging in trade-related transactions or dealings with Iran, including financing a prohibited transaction. A U.S. financial institution cannot so much as advise a letter of credit if the underlying transaction is in violation of OFAC regulations. In addition, U.S. persons are prohibited from facilitating transactions by foreign persons that would be prohibited if performed by a U.S. person.
A U.S. financial institution interdicts a commercial payment destined for the account of XYZ Import-Export Co. at the Bank of XYZ in Iran. The Bank of XYZ is an Iranian financial institution and wholly-owned by the Government of Iran; accordingly, Bank of XYZ is blocked under section 560.211 of the ITSR. This payment must be blocked.
A U.S. financial institution interdicts a commercial payment destined for ABC Import-Export in Tehran, Iran. Unlike the Bank of XYZ, ABC Import-Export in Tehran is not a blocked person, so there is no blockable interest in this payment. However, processing the payment would mean facilitating trade with Iran, exporting a service to Iran, and engaging in trade-related transactions with Iran; therefore, the U.S. financial institution must reject the payment.
When your interdiction software or account holder checking service shows a potential match, OFAC recommends that you do an initial analysis prior to contacting OFAC. If you have a reasonably close match to a name on the Specially Designated Nationals (SDN) list (or one of OFAC's other sanctions lists) and your customer is located in the same vicinity as the SDN, feel free to contact OFAC. Computer software may flag some transactions that are not actually associated with OFAC targets. This is where human intervention becomes critical and some hands-on research may be necessary. Please look at the following "due dilligence" steps before calling OFAC. Unless you have an exact match or are otherwise privy to information indicating that the hit is a sanctions target, it is recommended that you do not actually block a transaction without discussing the matter with OFAC.
In those programs with blocking provisions, OFAC's regulations block all "property" in which a target has an interest. The term "property" is very broadly defined, including present, future or contingent interests. In the case of a wire transfer, the bank will be holding blocked property upon the receipt of concrete instructions from its customer to send the funds. In this case, the funds must be blocked and reported to OFAC within ten days. If, on the other hand, a customer simply asks "Can I send money to Cuba?" there is no blockable interest in the inquiry and the bank can answer the question or direct the customer to OFAC. The same logic applies to cases where the transaction would be required to be rejected under OFAC regulations. There is not technically a "reject" item until the bank receives instructions from its customer to debit its account and send the funds.
It's a natural fact that every mammal has to pee. Eating, you can hold off for a few days, pooping is optional (for a while anyway), but peeing is right up there with breathing on the list of things you just gotta do each and every day. So when something happens to stem the flow of pee, trouble ensues - and fast.
Managing these cases medically can go way beyond relieving the obstruction in some cases. First priority is fixing the plumbing problem: getting pee to flow. This is usually done with anesthesia and a catheter to get the obstruction out of the way. Managing all the havoc wreaked by the toxins is next. This can necessitate some fancy medical dancing as we try and put all the genies back in their bottles. Disorders of deadly potassium, elevated renal values and severe dehydration can mean days in the hospital, even long after the pee is flowing again. It can get complex, expensive and can wear down even the most committed of owners for the really medically complex (and expensive) ones.
Our knowledge of contributing factors and therapies has surely changed and improved, but some days I feel like I am handling these cases the same way today as we did when I was a veterinary technician 20 years ago. Today cats with this disease do go home and get better, and even for the tough cases we can prevail and we have some tricks up our sleeve. Someday, science will provide an answer. I just want some means to prevent this disease in the first place, or some surefire way to treat it. I hope the future holds some promise, but I am not holding my breath. Or, well...you know.
My cat currently has a blockage. Last year he was peeing blood and I rushed him to the vet. The cat had a slight urinary blockage that they were able to clear out without too much cost. However now, we have one yet again. This time it's more serious and has to be removed via catheter. The hospital called me, good news they removed it! Bad news, it was a seriously complex obstruction and she told me surgery might be in the near future. I spent half my care credit on this and the surgery costs more than the other half. I know the cause of these obstructions. It's stress. I spoke to the vet and basically, he can be prescribed a urinary diet and prozac for the stress. I feel like I failed him as a cat mother and my bank account is paying for it.
He was acting off Saturday night and licking his bits and growling I didn't think much of it and went to bed he seemed fine, at 4am he woke me up crying and wailing in pain. We rushed him to the emergency vets, they explained he had a uti and potentially blocked. They claimed he managed to pee so he was sent home with anti biotics.
The whole day he was crying in pain, sad, low energy, he wouldn't eat or drink and he tried continuously to use the litter tray but couldn't, I knew he was declining and in pain. It broke my heart to see my healthy boy so sad. We took him back that night to the vet and they explained his soft bladder earlier in the morning had become rock hard and they couldn't do anything for him but surgery. It was explained this would be his life going forward with surgeries and potential blockages moving forward. We choose to put our boy out of pain that night. I cuddled and patted him for comfort and told him how much I loved him. I was with him when he crossed rainbow bridge, I held his paw and patted him as they sedated him and made sure I was the last thing he saw as he closed his eyes for the final time. R.i.p my angel. I'm devastated you left us under terrible circumstances ?
This disease is absolutely horrendous and devastating. With my little guy, it started about two years ago when he started going in and out of the litter box while howling. I didn't know what was wrong so I did some googling and read about obstructions. He went to the vet and got unblocked but I didn't know it would likely be a recurring thing.
He was eventually diagnosed with feline idiopathic cystitis. We tried everything and spent money we didn't have (both 22 at the time this started). We tried the special diets, removing all stress triggers, water fountains. But this issue just seemed to happen at random. He could be the happiest little cat one minute and the next minute, blocked. There was no rhyme or rhythm.
My guy didn't get complete blockages each time he had a flare up of cystitis. Even when he wasn't blocked, he was always in discomfort when peeing. The blockages happened three times in total. We had been told before about perineal urethrostomy (PU surgery). This was supposed to correct the issue by widening the urethra and making more space for him to pee. I thought at first I would never put him through it.
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