OFAC warns that foreign financial institutions continuing to transact with sanctioned entities may be targeted at any time without prior notice, and that sanctions risks may also be transmitted to cross-border payments through correspondent banks and intermediary institutions. The article notes that companies need to review not only the payee but also the payment route, dollar clearing relationships, and alternative channels; richer payment data such as ISO 20022 can help reduce opacity across the payment chain.
推荐理由：The article extends sanctions compliance from payee screening to correspondent banks and clearing routes, helping companies understand why cross-border payments may become unavailable because of a bank in the payment chain.