“financial transaction” broadly to encompass any transfer of
value involving a financial institution. For example, the following is a non-exhaustive list of activities
that OFAC would consider to be a “financial transaction”:
• The receipt or origination of wire transfers;
• The acceptance of commercial paper (both retail and wholesale), and the clearance of such paper
(including checks and similar drafts);
• The receipt or origination of ACH or ATM transactions;
• The holding of nostro, vostro, or loro accounts;
• The provision of trade finance or letter of credit services;
• The provision of guarantees or similar instruments;