BSA/AML Examiner School Case Study

Internal Use Only

addresses in the CIF Master File will be screened with the updated OFAC Listing. Two reports with the results will be reviewed by the BSA Department. Any positive matches will then be verified with the Office of Foreign Assets Control for clarification and confirmation of the match. If there is a positive match, the BSA/OFAC Compliance Officer will follow the instructions given by the Office of Foreign Assets Control. Update Scanning for OFAC Reports are generated by the FIS/OFAC Tracking SYSTEM every time our customer database is scanned with a new OFAC Listing. These reports are reviewed by a designated person. CIF OFAC Suspects ( OFAC_CIFM307 report) — List all existing customers by CIF numbers that are OFAC suspects. Structure of Accountability • The BSA Officer is responsible for the overall bank compliance with OFAC regulations. They will report to the Board of Directors and Senior Management concerning compliance reviews of the reports, impact of new regulations or changes to existing regulations and general compliance issues and concerns. • Maintaining current copies of applicable compliance statutes, regulations, interpretations and the Specially Designated National (SDN) list or NS-PLC lists. • For the day-to-day compliance of the OFAC Compliance Program, including the annual reporting of blocked or rejected transactions to OFAC, litigation reports and the oversight of blocked funds. • Maintaining proficient knowledge of applicable compliance statutes, regulations and interpretations. • Formulating and updating bank policies and procedures to maintain bank compliance with applicable compliance statutes, regulations and interpretations. • Coordinating the training of bank personnel on bank compliance policies and procedures. • Monitoring blocked funds, if any. • The BSA/OFAC Officer will file a report on rejected items within 10 days. This report will contain at minimum: The date and amount of the transfer; a photocopy of the payment or transfer instructions received; the basis for rejection; and the name and telephone number of a contact person at the transferee bank from whom compliance information can be obtained. Reports of rejected transfers are to be filed with the Compliance Programs Division office. • The BSA Department will report blocked property to OFAC within 10 days of the date the property is blocked. The reporting requirement for blocked property applies to any form of tangible or intangible property that is blocked pursuant to the OFAC Regulations. The reports are to be transmitted to OFAC Compliance Programs Division and must identify the minimum requirements specified by OFAC. • Total amounts blocked, including interest, will be reported by the Bank to OFAC by September 30 of each year (information as of June 30). Annual reports must be filed using the form entitled "Annual Report of Blocked Property." • The OFAC Officer will report to OFAC U.S. persons involved in litigation, arbitration or other binding alternative dispute resolution proceedings regarding blocked property by: Providing notice of such proceedings to OFAC Chief Counsel; Submitting copies of all documents associated with such proceedings within 10 days of their filing to OFAC Chief Counsel; and Faxing information about the scheduling of any hearing or status conference to OFAC Chief Counsel.

For Training Purposes Only

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