I'm fairly new to compliance. We do not have a separate written OFAC Policy. Is this required? We do have OFAC written procedures. Thanks for your help!

Checking with OFAC can be incorporated with your BSA and Know Your Customer Policy or a separate policy - it's your option.

IMHO, OFAC and BSA are two separate items, and for that reason, I would keep them separate.

Oh, and Paragon, I just love that dancing cow!

We keep them separate, in fact, we have separate policies for BSA, AML, OFAC and CIP but they're all under our BSA "program".

IMHO, OFAC and BSA are two separate items, and for that reason, I would keep them separate.

Oh, and Paragon, I just love that dancing cow!

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Unless, dealing with this stuff is only a small part of what you do all day! Besides, they are in many ways related regulations, not entirely separate issues.

Also, that is a fighting cow - not a dancing cow.

We also have separate policies but they all fall under the BSA "umbrella".

I've found that it impresses the heck out of the examiners when you give them OFAC procedures.

Our bank had its Safety & Soundness Exam a few months ago, and the FDIC stated that although we had an OFAC Policy and Procedure in place, they recommended that we "beef" up the content of the procedures, specifically, procedures for reporting blocked/rejected transactions to OFAC.