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OFAC Policy Available
If you have access to the Internet, you might want to try http://link-usa.com/ofac/ofacpro.htm
and print out a copy of Bridger System's sample OFAC Policy and Procedure Guide. It has a little over two pages that you could retype and use as your OFAC Policy and Procedure Statement. Your examiner will be looking for one.
A warning-BE SURE YOUR POLICY AND PROCEDURES MATCH THE STATEMENT! If not, either adjust your procedures, or adjust the statement!
Copyright © 1997 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 7, No. 11, 9/97
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