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OFAC: What You Should Be Doing
(Presented by Mary Beth Guard)
Is your OFAC risk assessment ready for examiner scrutiny?
Do you conduct independent testing of your OFAC program?
How do the new BSA exam procedures affect your OFAC program?  | WEBINAR TIME:
11:30AM - 1:30PM PT
12:30PM - 2:30PM MT
1:30PM - 3:30PM CT
2:30PM - 4:30PM ET |  |
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As banks seek to comply with the OFAC requirements, there's clearer guidance than ever before. The Office of Foreign Assets Control has continued to update its set of Frequently Asked Questions, and the new Bank Secrecy Examination procedures released in June 2005 include an overview and procedures for examining a bank's policies, procedures, and processes for ensuring compliance with OFAC sanctions.
Based upon the new exam procedures, the examiners may review your institution's OFAC risk assessment, your independent testing of your OFAC program, your OFAC-related policies, procedures and processes. Will yours be up to the test?
Have you done an OFAC risk assessment?
Have policies, procedures and processes been developed by your board and senior management, based upon that risk assessment?
Have procedures for OFAC searches been developed and properly implemented for all of the relevant departments/business lines?
Has responsibility for OFAC compliance been assigned?
Does your institution obtain and update the OFAC lists or filtering criteria on a timely basis?
Do you have solid procedures for investing potential matches?
Do you have a process for blocking and rejecting transactions?
Are you familiar with the timing requirements for OFAC reports?
What kind of independent testing are you performing on your OFAC procedures?
Have you established workable follow-up procedures?
Are your employees properly trained on OFAC?
What should you be doing to comply? Mary Beth Guard will discuss the practical aspects of your compliance program. Ensuring the content of your board approved policies, procedures and practices are based on a current risk assessment is the first step. Knowing what has to be in these documents is key. It is also important to know that you have a method to keep your OFAC lists up to date and how often to check each new account and the portfolio overall against this list.
Other topics included in the plan English discussion include:
how far OFAC searches need to go and which records need to be checked
who has OFAC responsibility in your institution
your processes to verify possible "hits" or matches
handling blocked or rejected transactions
record retention
independent testing and follow up
Whether you are a seasoned compliance or audit professional, a supervisor in the New Accounts or Loan department or an employee who has to face a customer and explain why these rules apply, this webinar will be of interest to you. Ensure that the OFAC portion of your BSA program is what it needs to be, from beginning to end.
More information...
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888-229-8872