BSA/AML Examiner School - Case Study Oct 2023

LCB12115

Checklist 13.1: OFAC Review Procedures (cont.)

No

N/A

• The timing of the search?

.---Y . 7 - -- \

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.IF c

• The documentation maintained evidencing the searches?

N'D

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Comments: *BSC is unable to comment on or assess its own product

-

Use the followirps rs t. thenrsti ution uses an

-el - c s stem

AC searches.

automated

P?)

Yes

No N/A

updates made to the system in a timely manner after OFAC published he updated list or information? Are all of the institution's databases run against the automated system once they are updated?

Y

1

Y

Are the databases run against the updated system in a timely manner?

Y

Run tests of the system by entering test account names that are the same as r similar to those recently added to the OFAC list. Did the system identify tho otential "hits"? .-----Isi Comments: Data Base Verification — The Bank's entire data base is searched on a monthly basis. In addition, the data base is searched when new OFAC updates are received. The 12/10/2015 "Batch Detail Report" was reviewed. Three_possible matches were identified and were determined not to be matches. OFAC Verification — The Bank completes OFAC at account opening through the FIS core system, loans through credit reports and wire transfers through Bankers Bank of Tennessee. Validation Testing — Request list responses indicate that the Bank does not complete testing to validate the OFAC search application for accuracy or updates to the system. Recommendation — Periodic testing for accuracy and updates is recommended as a best practice.