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#2162623 - 01/31/18 07:46 PM OFAC officer
Compliance Action Subscriber 1226 Offline
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Joined: Sep 2015
Posts: 198
Can the CO be the BSA officer and the OFAC officer - we are a small institution and the person doing OFAC has resigned

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BSA/AML/CIP/OFAC Forum
#2162625 - 01/31/18 07:48 PM Re: OFAC officer Compliance Action Subscriber 1226
bcompliance Offline
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Joined: Sep 2014
Posts: 1,294
Yes, every small bank I have worked for has that setup. You just want to make sure they have the correct resources to do all of their jobs. Whether that is hiring an assistant or other staff members to work under them, they need to be able to get all of their duties done sufficiently.
Last edited by bcompliance; 01/31/18 07:50 PM.
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#2162640 - 01/31/18 08:17 PM Re: OFAC officer Compliance Action Subscriber 1226
Compliance Action Subscriber 1226 Offline
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Joined: Sep 2015
Posts: 198
thank you

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#2162661 - 01/31/18 09:31 PM Re: OFAC officer Compliance Action Subscriber 1226
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Spread the joy and break down these responsibilities among different people. (OFAC is not that tough for most community banks; it's about planning for something that never actually happens.) Otherwise, when the next person quits, you will be in the same situation you are in now.
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#2162763 - 02/01/18 06:16 PM Re: OFAC officer Compliance Action Subscriber 1226
P*Q Offline

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P*Q
Joined: May 2001
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I am all three of those and the Security Officer and the Compliance Officer and it has not been an issue other than an examiner, commenting in an exit meeting to the CEO and the President, "she wears a lot of hats".

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#2162779 - 02/01/18 07:12 PM Re: OFAC officer P*Q
ItNeverEnds CRCM Offline
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Joined: Oct 2006
Posts: 995
Looking for my sanity
Originally Posted By P*Q
I am all three of those and the Security Officer and the Compliance Officer and it has not been an issue other than an examiner, commenting in an exit meeting to the CEO and the President, "she wears a lot of hats".


Ditto here. In addition to everything above, I'm also the Information Security Officer.
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