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Question & Answer
Question: How important is compliance with OFAC? Our compliance examiners don't generally look at OFAC compliance.
Answer: Don't take your direction on this from your bank's compliance examination. The bank regulatory agencies are not the enforcement agency for these regulations- the Office of Foreign Asset Control is. Because of the severe penalties for non-compliance, your bank examiner will check to see that you have an OFAC compliance program and may even do a little to evaluate its effectiveness. However, the real nuts and bolts of the program are up to the bank. So don't let the apparently superficial attention given by your examiner lull you into thinking that this isn't important. OFAC compliance is very important. Penalties are non-discretionary if the bank is caught handling a transaction that should have been blocked.
Copyright © 1997 Compliance Action. Originally appeared in Compliance Action, Vol. 2, No. 9, 8/97
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