BSA/AML Student Exercises Dec. 2022

LCB 12/15

Checklist 13.1: OFAC Review Procedures (cont.)

No N/A

p'es

 The process used to investigate potential matches?

Y

1 Y

 The process used to block and reject transactions?

7

 The process used to inform management of blocked or rejected transactions?

Y

 The adequacy and timeliness of reports to OFAC?

y

 The process to manage blocked accounts (such accounts are reporte ' to OFAC and pay a commercially reasonable rate of interest)?  The record retention requirements (i.e., five-year requirement to retain relevant OFAC records; for blocked property, record retention for as long as blocked; once unblocked, records must be maintained for five years)?

y

, i Y

1

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,...

Are the bank's independent testing (audit) and follow- up procedures adequate?

y

g9 t .,10

-1 2:> 151

Is the institution's OFAC training program adequate given the institution's OFAC risk assessment? Y Has the institution adequately addressed weaknesses or deficiencies previously identified by OFAC, auditors or regulators? Review the institution's filtering procedures for transactions (such as wire and other funds transfers, letters of credit, and non-customer transactions). Are the filtering procedures adequate in terms of:

NA

 The filtering criteria used to search the OFAC database?

I

(6 7

5 0