The FDIC’s Risk Management Manual of Examination Policies lists specific OFAC-related questions being asked by regulators during examinations, including the following:
- Does the institution have policies and procedures in place for complying with OFAC laws and regulations?
- Does the institution maintain a current listing of prohibited countries, entities and individuals?
- Is the OFAC information disseminated to foreign country offices?
- Are new accounts compared to the OFAC listings prior to opening?
- Are established accounts regularly compared to current OFAC listings?
Are you prepared to answer these questions when the examiners visit? No institution is too small—no city too remote to be affected by terrorist activities.
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