OFAC Policy Update

Office of Foreign Assets Control Policy Update - 02/21/06

Bankpolicies.com is proud to announce the immediate availability of our revised Office of Foreign Assets Control (OFAC) Policy Template product.

The revision to this product is in response to the FDIC's FIL 9-2006 "Economic Sanctions Enforcement Procedures for Banking Institutions" dated 2/1/06. The interim final rule, which supersedes OFAC's proposed rule of January 29, 2003, is effective with enforcement cases involving banking institutions commencing on or after February 13, 2006.

http://www.fdic.gov/news/news/financial/2006/fil06009.html

What's New

Topic 3 - OFAC Background, Enforcement and Penalties. Contains an overview of OFAC requirements including the following subtopics:

General

OFAC's Evaluation of Conduct Violations

Periodic Institutional Review

Factors Affecting Administrative Action

License Suspension and Revocation

Civil Penalties

Criminal Penalties

Topic 5 - Structure of Accountability. Lists the responsibilities of a financial institution's board of directors, senior management, compliance committee and Bank Secrecy Act/OFAC officer.

Topic 6 - Risk Management. Addresses a financial institution's OFAC risk management program including the following subtopics:

General

Quantity of Risk Standards

Banking Operations and Background

Products and Services Offered

Topic 13 - Retention of Documentation. Provides a brief record retention statement.

What's Revised

Topic 2 - Policy Statement. Expanded to include an overview of key elements of a financial institution's OFAC compliance program.

Topic 4 - Definitions. Several new definitions have been added.

Topic 7 - Screen and Blocking Processes. Repetitive financial institution employee procedural statements were removed for grammatical purposes.

Topic 9 - Automated Clearing House Transactions. The text of a financial institution's requirement to ensure appropriate language in its ACH origination agreement(s) was simplified.

Topic 10 - Department Policies and Procedures. The following subtopics were added in addition to the removal of repetitive financial institution employee procedural statements for grammatical purposes:

Non-Customer Transaction Monitoring

Customer Information File Inquiries

Topic 11 - Staff Training. Additional employee training requirements were added.

Topic 12 - Audit Policy. Additional OFAC audit scope requirements were added.

Product Contents

Purpose and Contents - Topic 1

Policy Statement - Topic 2

OFAC Background, Enforcement and Penalties - Topic 3

Definitions - Topic 4

Structure of Accountability - Topic 5

Risk Management - Topic 6

Screening and Blocking Processes - Topic 7

Rejecting Transactions - Topic 8

Automated Clearing House Transactions - Topic 9

Department Policies and Procedures - Topic 10

Staff Training - Topic 11

Audit Policy - Topic 12

Retention of Documentation - Topic 13

Ordering Information

This revised product is available to purchase from Bankpolicies.com for:

$225.00 - List Price

- or -

$100.00 - Update Price (applies only to clients who have previously purchased our Office of Foreign Assets Control (OFAC) Policy Template product)

If you have ordered this product after 1/21/06 you are eligible to receive the Product Update at no charge.

Click here to place an order for this product. Clients who are eligible for our Legacy Rewards Volume Discount can apply their applicable discount level to the upgrade or list price (whichever applies).

NOTE: Refer to our Place an Order page for important information regarding payment terms and our return policy. Orders placed for Product Updates are only available directly through Bankpolicies.com.