A bank has a zero-tolerance policy for conducting activity with sanctioned entities or countries.

When a bank has a zero-tolerance stance regarding sanctioned jurisdictions and no applicable license or exemption exists, the appropriate response is to reject and return the remittance, informing the sending bank that the transaction cannot be processed for sanctions compliance reasons.

Escalation for consideration is inconsistent with a zero-tolerance policy. Filing a SAR does not authorize processing a prohibited payment. Processing on the assumption of a license without one presents regulatory violations.