(2) the nature of the
transaction(s); (3) the level of awareness of management and whether the transaction(s) are part of a
pattern of conduct; (4) the nexus between the transaction(s) and a blocked person; (5) the impact of
the transaction(s) on statutory objectives; (6) whether the transaction(s) involve deceptive practices;
and (7) such other factors that the Secretary of the Treasury deems relevant on a case-by-case basis.
For purposes of section 5 of UFSA, a transaction is not significant if U.S. persons would not require
specific licenses from OFAC to participate in it.
[…]
OFAC will generally interpret the term “financial