I wasn't sure where to post this, so this forum was the winner.

We are currently in the process of updating our Business Continuity plan to include procedures in the event there is a pandemic flu outbreak. Because there are certain timeframes that need to be adhered to under BSA/OFAC/Patriot Act, I am wondering what is going to happen in the event we are shut down and can't do OFAC or 314(a) for example.

I know that we are supposed to plan for remote access and we are, but the BSA function has not been considered in that process as critical.

Have others addressed this issue yet, and if so what are you planning to do? I have also emailed the regulator to see what they have to say.

Thanks in advance.

In our shop, compliance sits in on all the BCP sessions, planning and testing.

On a related note, this year we moved away from having 8,000,000 separate contingency plans (pandemic flu, pandemic flu during a snowstorm, pandemic flu + electromagnetic pulse, etc.)to classifying the effect; access to workplace, access to systems, access to communications network, for example. You can still have a good time spinning the big 'wheel of misfortune' if you want, but your reactions are all going to fit in broad categories (did our office close? did the one on the west coast close? do we still have access to our systems?)