Unauthorized Business Activity

Last Updated

January 10, 2025

BILL complies with OFAC regulations and has a robust OFAC compliance program. BILL does not facilitate, directly or indirectly, interactions with the following:

Comprehensive country sanctions

Sanctions can be comprehensive or specific to a country, individual, or entity (e.g., businesses). OFAC sanctions apply to US citizens, residents, and entities, regardless of their location.

Comprehensive country sanctions are the most broad-based prohibitions and prohibit a US Person (individual or entity) from dealing in various activities with a country, such as import/export, trade, financial transactions, etc. Comprehensive country sanctions are currently imposed on:

  • Burma/Myanmar
  • Crimea Region of Ukraine
  • Donetsk People's Republic (DNR)
  • Luhansk People's Republic (LNR)
  • Cuba
  • Iran
  • North Korea
  • Syria

BILL does not support interactions with Russia, even though it is not a comprehensively sanctioned country.

Specially Designated Nationals (SDNs)

In addition to comprehensively sanctioned countries, and as part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for, or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers, designated under programs that are not country-specific. Collectively, such individuals and companies are called “Specially Designated Nationals” or “SDNs.” US persons, including individuals and entities such as BILL, are prohibited from dealing with SDNs, including facilitating payments to or on behalf of SDNs.