Unless I'm not following, there is no debate about whether the Balkans region is sanctioned by OFAC or if Bulgaria is included in the Balkans. But, as I understand it, Bulgaria itself isn't sanctioned. It's not the equivalent of Iran today or Cuba 10 years ago. It is permissible to process wires for Bulgaria assuming that the originator or beneficiary is not a sanctioned party.
Agreed. 100%.
|