Is there any reason why our Wire Room could not perform their own OFAC approvals for wires? They're claiming it needs to have a separation of duties.

We have a unique situation, the BSA Department is not housed at the main office but in a branch. The branch closes at 4 and we leave when they do, anywhere from 4:30 to 4:45, leaving a window of about 15-20 minutes for possible OFAC approvals. Our wire room doesn't close until 5. We then have to drive to the main office for 15-20 minutes to approve OFAC if needed, because the Operations Manager refuses to allow her staff to approve the OFAC. We have made up spreadsheets of all the false positives and why they are false positive as there has never been an actual match. They're very repetitive and simple one word matches.

I'm trying to find a concrete argument to persuade senior management why they are being ridiculous in their decision. At other institutions on Friday nights and Saturdays, the Branch Managers were able to approve any false positives and we would oversee them on Monday as the BSA Department did not work Friday nights and Saturdays.

If they have a potential hit, why don't they just have the manager sign off on it? If she's properly trained, I'm not sure why anyone would have an issue with this as long as there is oversight by the BSA/Compliance department.

That's our point too. But they are pushing back that it is not a segregation of duties since they are releasing the wire. I'm not sure if we just aren't explaining it well or they just don't understand, doing an OFAC approval has nothing to do with releasing a wire. Verifying and releasing a wire may be a problem and not a segregation of duties, but it has nothing to do with approving OFACs.

Sounds like they don't understand.

we have a multi-step ofac process...initial hit it is reviewed by a senior wire operator, if they can determine it is a false positive they approve and off it goes. if they can't determine, it goes to the supervisor or manager in wire for their review. if they can determine false positive, they release and it goes. if they can't, it is then routed to a supervisor in our BSA area for them to make a determination.

the separation of duty issue is only in their head.

Our OFAC compliance team reviews all potential OFAC matches rather than wire room staff. Once upon a time, we had the wire staff review and release them; however, we also had an instance where the processor released a wire being sent to Cuba. We have been paying the price for that single infraction for upwards of 6 years now which is why the review isn't being completed by the wire department. I don't see it going away in my lifetime.

At any rate, is there any way to either have someone stay at the branch until 5 or change the wire cutoff time to match when the OFAC review staff leave? It seems like there should be a way to meet in the middle.