A company discovers it unknowingly violated an OFAC sanction by processing a payment involving a Specially Designated National (SDN). Which is the MOST appropriate immediate first step?
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A
Immediately disclose to OFAC and cease operations pending investigation
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B
Block the transaction or property if possible and conduct an initial internal review
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C
Issue a press release to notify the public of the potential violation
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D
Terminate all employees involved in the transaction