Examiners' post-9/11 approach to OFAC

Question: Since September 11, have examiners changed their approach to examinations for OFAC compliance?

Answer: Prior to the terrorism of last fall, examiners gave some attention to a bank's OFAC compliance efforts. But this generally amounted to determining that the institution actually had an OFAC compliance effort. Now, however, examiners realize the importance of OFAC compliance to our safety. You can expect examiners to pay more attention to OFAC compliance. Also, as regulations are issued under the USA PATRIOT Act, there will be more attention given to BSA matters - especially account-opening procedures.

Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 5, 5/02