OFAC Policy Update

Office of Foreign Asset Control Policy Update 09/12/06 Detail

Topic 3 - OFAC Background, Enforcement and Penalties. A new subtopic "OFAC Licenses" was added to provide an explanation of the term.

Topic 6 - Risk Management and Assessment. The following subtopics were completely revised to include greater details:

General

Customer Base

Geographic Locations

Product and Services Offered

The following subtopics were added at the request of numerous clients to provide detailed examples of specific risk assessment guidelines:

OFAC Risk Assessment Program

Parallel Banking

Correspondent Accounts

U.S. Dollar Drafts and Payable Through Accounts

Pouch Activities

Electronic Banking

Wire Transfers

Automated Clearing House Transactions

Electronic Cash

Third Party Payment Processors

Sale of Monetary Instruments

Brokered Deposits

Privately Owned Automated Teller Machines

Non-Deposit Investment Products

Insurance

Concentration Accounts

Lending Activities

Trade Finance Activities

Private Banking

Trust and Asset Management Services

Topic 7 - Screening and Blocking Processes. Two paragraphs were added at the beginning of the "Blocking Requirements" subtopic to further explain minimum regulatory requirements.

Topic 8 - Rejecting Transactions. The "General" subtopic was revised to mirror regulatory guidance.

Topic 11 - Audit Policy. This topic was completely revised to mirror regulatory guidance.

Topic 12 - Staff Training. The "General" topic was revised to incorporate additional minimum requirements.

A "Board of Directors" subtopic was added to provide specific training requirements for a financial institution's board of directors.

Ordering Information

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

$225.00 - List Price

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$50.00* - Update Price

*Applies only to clients who have purchased our Office of Foreign Asset Control Policy Template in addition to the following prior update (if applicable):

Office of Foreign Asset Control Policy Template Update - 02/21/06 - $100.00

If you have ordered this product after 08/12/06 you are eligible to receive the updated product at no charge.

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