Does anyone know approximately how many entities are on the OFAC List? Also, does anyone have any ideas about how to make this training more appealing to directors? I have some articles I plan to discuss on money laundering and on suspicious activity (that should have some applicability); and I briefly discuss penalties. But things can get rather dry after that.

I don't know how many names are on the list, but if you are trying to create an impression about how long it is, print out the first page to show to your directors and then let them know that there are 416 pages of names after that one!

SDN List

I used to start by pulling a few names such as "John Abbott" and "Atlas Air Conditioning" and asking what those names had in common. That got their attention because I think there was an expectation by some that the names on the list would all be foreign, so easily identifiable.

I always printed out the entire list to use it for visual effect.

The sheer size usually got their attention.

You could do that with the BSA Exam Manual, too.

I agree, the basics of OFAC and BSA can be dry. These are some examples of how I spruce it up. I share a few examples of OFAC/AML penalties throughout the year. I list a few financial institutions, major corporations and individuals followed by the reason for the penalty. The $6,056.50 OFAC fine for an individual that purchased Cuban cigars over the internet gets their attention! Several years ago, I believe it was the New York Yankees that was fined by OFAC for sending wires to Cuba, that also raised eyebrows with the Board. Last year, former Governor Spitzer also was a prime example of a SAR filing which the Board recognized. Another item the Board likes to see is a summary of SARs filed by your institution. I break down the numbers according to the SAR category and provide the total dollars filed by category. I compare the Bank's numbers against FinCEN's national SAR totals.

WOW some terrific information and ideas. Thanks to everyone.

Personal favorite: Playboy Enterprises, Inc. $27,500 for doing a photo shoot in Cuba.

Does anyone really think they cared?

Directors always ask me how they should respond when customers ask about CTR reporting...we usually discuss just telling customers to do their transactions and not worry about reporting limits, thereby avoiding any problems. One director asked for advice he could use short of pulling a brochure out of his pocket at a cocktail party!

Golfer9,

I agree with Slim-el's method--you have to get their attention up front--use something they can relate to, like the Cuban cigars--and also BrendaC's idea is good--this gets them to understand the scope of the list and how common names often create near matches that must be investigated.

Our directors like facts and figures and short presentations. I provide data on our bank's activity - maybe how many foreign wires we do and the counties they go to, types of persons or business doing the activity. Volume changes from prior year, # and type of high risk customers as well as some industry stats on enforcement actions, fines etc. Brief summary of any regulatory changes.