OFAC Policy Update Details

Product Update Notification - 12/07/09

Office of Foreign Assets Control Policy Update Details

What's Revised

Topic 3 - OFAC Background, Enforcement and Penalties. The following subtopics and related bullet points were revised:

Types of Responses to Apparent Violations:

4 - Finding of Violation.

5 - Civil Monetary Penalty.

6 - Criminal Referral.

Civil Penalties for Failure to Furnish Information or Keep Records - entire contents.

Civil Penalties:

1A - Civil Penalty Process (third and last bullet points).

2B - Amount of Civil Penalty/Pre-Penalty Notice (entire contents).

In addition, the following subtopics were deleted:

Periodic Institutional Review

Criminal Penalties

Topic 4 - Definitions. The first paragraph of the "Voluntary Self Disclosure" definition was revised.

Topic 6 - Risk Management and Assessment. The following changes were made to bullet points of the "Quantity of Risk Standards" subtopic:

1 (Low Risk Financial Institution Standards) - New bullet points O - T were added.

2 (Moderate Risk Financial Institution Standards) - New bullet points P - U were added.

3 (High Risk Financial Institution Standards) - New bullet points P - U were added.

Ordering Information

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

$275.00 - List Price

- or -

$25.00* - Update Price

*Applies only to clients who have purchased the Office of Foreign Assets Control Policy within the last three years including the following updates (if applicable):

Office of Foreign Assets Control Policy Template Update - 12/15/08 - $25.00

Office of Foreign Assets Control Policy Template Update - 09/30/08 - $75.00

Office of Foreign Assets Control Policy Template Update - 09/27/07 - $50.00

If you have ordered this product after 11/07/09 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 list or update 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.

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