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#382526 - 07/07/05 07:05 PM OFAC Lists
kvmo Offline
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I have searched and searched and cannot find the answer to this remedial question. I know we are not supposed to maintain copies of the 314a list, but what do we do with the mountains of OFAC lists we have? Please help!

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#382527 - 07/07/05 07:18 PM Re: OFAC Lists
Hrothgar Geiger Offline
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What do you mean 'mountains of OFAC lists'? Each updated list supercedes the previous one.

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#382528 - 07/07/05 07:26 PM Re: OFAC Lists
Anonymous
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Are you saying we should keep only the most recent list and dispose of previous lists?

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#382529 - 07/08/05 10:30 AM Re: OFAC Lists
Elwood P. Dowd Offline
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As AML indicates, there is actually a core list to which additions and deletions are made. It is important that you be able to document that the list you use was "current" at the time you used it, but it is not necessary to keep copies of each variation of the list.
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#382530 - 07/08/05 12:46 PM Re: OFAC Lists
Hrothgar Geiger Offline
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Before making a reflexive "No we don't keep the old lists", I started to think that in the course of doing our system backups and archive, we probably wind up keeping an electronic copy of old lists. But no one keeps copies of them on paper.

Referring to Ken's point, what we wind up with is electronically auditable, you can show the version of the list you used for the comparisons recorded at the time.

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#382531 - 07/08/05 12:46 PM Re: OFAC Lists
First Banker Offline
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I heard or read somewhere that the list itself is to be destroyed once the search has been completed. It was recommended that a log of the serial number and date be maintained as proof that it was received and processed. Am I wrong?

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#382532 - 07/08/05 12:47 PM Re: OFAC Lists
Hrothgar Geiger Offline
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Quote:

I heard or read somewhere that the list itself is to be destroyed once the search has been completed. It was recommended that a log of the serial number and date be maintained as proof that it was received and processed. Am I wrong?


I'm pretty certain that refers to the 314a lists, not the OFAC lists.

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#382533 - 07/08/05 03:43 PM Re: OFAC Lists
Princess Romeo Offline

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Quote:

Quote:

I heard or read somewhere that the list itself is to be destroyed once the search has been completed. It was recommended that a log of the serial number and date be maintained as proof that it was received and processed. Am I wrong?


I'm pretty certain that refers to the 314a lists, not the OFAC lists.



That definately refers to the 314(a) lists. OFAC lists are freely available to anyone who cares to download the file from OFAC's website.

314(a) lists are protected by registration requirements in order to access.
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