314(a) Call Report
Question: What happens if we miss a customer who is on the OFAC list and the examiner finds it?
Answer: If an examiner finds a violation of OFAC, the agency will notify OFAC of the finding. From there, it is in the hands of OFAC.
The same thing happens when the examiners find a problem with BSA compliance. Failures in reporting CTRs will result in a notification to FinCEN. From then on, the remedial action or enforcement is in the hands of FinCEN just as OFAC takes over when a transaction has not been properly identified and blocked. So the best practice, after never making mistakes, is to find it and fix it before the examiners come in. Good luck!
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 7, 7/04
Privacy Policy Disclaimer Recommend This Site ! Contact Us
BankersOnline is a free service made possible by the generous support of our advertisers and sponsors. Advertisers and sponsors are not responsible for site content. Please help us keep BankersOnline FREE to all banking professionals. Support our advertisers and sponsors by clicking through to learn more about their products and services.
|
|
Print Friendly!
Email This Article!
Discuss NOW!