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OFAC Screening: Who and How Often?

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What information in a bank's data base is required to be screened against OFAC periodically? For example are guarantors, signatories and accounts payable vendors required to be scanned?

OFAC regulations do not require that any information in a bank's database be screened ever. The regulations DO require that you conduct an OFAC risk assessment and construct an OFAC compliance program responsive to that risk assessment. Your OFAC program should specify, based on the risk assessment, what information should be screened and how often. This will differ from bank to bank.

First published on 2/28/11

First published on 02/28/2011

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