Answer:
OFAC is a strict liability enforcement agency. They don’t require you to screen anything. They will simply enforce the law if you break it. It is the regulatory agencies that require you to have a risk-based approach that is commensurate with the risks of your institution. Your risk based decisions for lists to screen This may include scanning the OFAC list, the Commerce Department’s export denial list, etc. You need to scan the lists that your risk assessment indicates would be appropriate.
-----------------------------
Learn more about Tim White’s webinar
OFAC for Community Banks
print
share