We just had a FDIC BSA examiner tell us that it is required that all appropriate personnel receive OFAC training at least annually. I explained to her that most of our training had a component of OFAC and to prove it to her I printed the sections of the training and gave it to her. But she is adamant that its required annually. I am unable to locate the annual OFAC training she cited. Can you help?

You must be doing great if this is what the examiner is digging in on. We don't do separate training on OFAC, it is a component of our BSA/AML training.

If you're unable to locate the annual OFAC training she cited, have her show it to you.