31 CFR part 501, Appendix A: OFAC asks whether a company had reason to know of a violation (31 CFR part 501, Appendix A (Economic Sanctions Enforcement Guidelines), III.B.2)
A buyer that paid a blocked holder without checking can still be penalised if it should have known with reasonable due diligence. That is why buyers screen new holders.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“Reason to Know. If the Subject Person did not have actual knowledge that the conduct took place, did the Subject Person have reason to know, or should the Subject Person reasonably have known, based on all readily available information and with the exercise of reasonable due diligence, that the conduct would or might take place?”
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide