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#791409 - 08/08/07 08:10 PM Exam infomration request letter question.
SLBanker Offline
New Poster
Joined: Jun 2007
Posts: 7
We are have an exam in September and I am working on completing the Information Request Letter for BSA/AML. This will be a FRB exam.
The question (under OFAC) asked is: "The bank's risk management process relating to OFAC sanctions".

I can't answer that because I don't understand the question. Can anyone help?

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#791425 - 08/08/07 08:22 PM Re: Exam infomration request letter question. SLBanker
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
You should have an OFAC Risk Assessment, just like you have a Bank Risk Assessment.


If you have not done one as yet, - you need to.
Do a search on these Threads and you should find help...
Otherwise, someone here may have something to send you.

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#791445 - 08/08/07 08:35 PM Re: Exam infomration request letter question. SLBanker
ComplianceCreep Offline
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Joined: Jul 2006
Posts: 6
Ohio
We had the same question this year - I provided our written OFAC procedures for how and when all searches are performed, the board approved OFAC Policy and our most recent risk assessment which included OFAC risk, if any.

FYI - be sure your staff is properly performing the searches as required (all new customers, Payable To persons on cashier's checks purchased - if paid to non accountholders, wire transfers, etc...)

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#791525 - 08/08/07 09:35 PM Re: Exam infomration request letter question. SLBanker
Ted Dreyer Offline
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Ted Dreyer
Joined: Apr 2001
Posts: 2,245
See Appendix M of the BSA Exam Manual.

Appendix M

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#791631 - 08/09/07 12:45 AM Re: Exam infomration request letter question. Ted Dreyer
AnonRegulator Offline
Gold Star
AnonRegulator
Joined: Mar 2002
Posts: 451
Everywhere, USA
The examiners are simply asking for your procedures to ensure compliance with OFAC sanctions. If you have something in writing on this, provide it to them. Otherwise, describe what you do to ensure that your bank does not facilitate illegal transactions. AR.

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#791900 - 08/09/07 04:04 PM Re: Exam infomration request letter question. AnonRegulator
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
Best bet is to at least include Appendix M in your response together with a short write up in support of your ratings. For example, your records show " no international wires) in support of a low rating on funds transfers" or "only 20 customers out of 2200 are non-res aliens". This together with your OFAC policy and procedures should be just fine.

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