The OFAC regulations have been amended; they now provide that a person "otherwise associated" with individuals whose property and interests are blocked by OFAC includes one who:

• Owns or controls such persons, or
• Attempts, or conspires with one or more persons, to provide financial, material or technological support, or financial or other services, to such persons.

These definitions are so broad that they might be applied to individuals in legitimate commerce who have no knowledge of the terrorist inclination of the OFAC-blocked person.

The bar may now have now been raised. Arguably, any bank employee with provides financial services to persons whose assets are blocked by OFAC could be considered a Terrorist Affiliate. Since OFAC sanctions are abruptly placed, often without prior warning, daily, or even twice-daily, access to World-Check with respect to your client database, should now be considered mandatory.