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Economic sanctions remain a primary tool used by the U.S. government to achieve foreign policy goals. The last several years have seen significant enhancements to the various OFAC lists, particularly those that relate to Venezuela, Iran and Crimea. While historically, sanctions risk for credit unions was low, in the past few decades there has been significant growth in the size of credit unions, the consumer bases they serve and the products they offer. This has introduced new types of risk for credit unions, one of which is that a member or partner could engage in transactions with sanctioned entities.

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