i've just read the "bol" article "differences between the control list and the ofac list". one ? (for now), p. 2 notes that institutions are required to review their records from jan 1, 1996 to the present. how is this done(easily) in light of records retention issues, etc. is this a firm requirement? how are you folks addressing this/ as usual, thanks for your help.

The Control List no longer exists. Technically, it was never a legal requirement. Although it certainly did not appear that it was something your bank could simply refuse to do, compliance was not required by law.

Thus, if you decide to keep records of your searches, what records you keep and how long you keep them is purely up to you.

thanks, ken. i am surprised to hear that. our bank's chief counsel receives a "control list" monthly which is forwarded to appropriate area for research. any document stating this list is now obsolete? thanks again.

You might want to check the FinCEN web site to look for the announcement that the Control List was discontinued. What you are recieving now are referred to as "314(a) Queries."

Ken is correct. The notices you are now receiving should be coming every two weeks. This is in guidance of the 314(a) request and is not considered the control list.

thanks again, ken. appreciate it.

thanks tina

tom, thanks.