OFAC Compliance Checklist

I. Compliance Program Overview

Company Commitment: Declare [YOUR COMPANY NAME]'s commitment to OFAC compliance.
Responsible Party:[YOUR NAME], [YOUR DEPARTMENT]
Date of Last Review: [DATE]
Next Scheduled Review: [DATE]

II. Risk Assessment

Conduct an extensive risk assessment to identify potential exposure to sanctioned parties and countries.
Assess business actions, locations, and customers to identify risks.
Document risk assessment findings and establish risk mitigation strategies.

III. Screening Procedures

Screen customers, vendors, and business partners using robust procedures against OFAC's SDN list.
Utilize automated screening tools and software to enhance efficiency and accuracy.
Conduct periodic screenings and update screening procedures as necessary.

IV. Transaction Monitoring

Establish transaction monitoring systems to detect and flag suspicious transactions or activities.
Define thresholds and criteria for triggering alerts and conducting further investigation.
Train staff members responsible for transaction monitoring on identifying red flags and reporting procedures.

V. Due Diligence

Conduct due diligence on new customers, vendors, and partners to prevent illegal transactions.
Verify the identity and background of counterparties through reliable sources.
Document due diligence efforts and maintain records for audit purposes.

VI. Employee Training

Provide comprehensive training to employees on OFAC regulations, policies, and procedures.
Offer regular refresher training sessions to reinforce key concepts and updates.
Encourage employees to report any potential compliance concerns or issues promptly.

VII. Record-keeping

Maintain accurate records of OFAC compliance efforts, including screening results, due diligence documentation, and training records.
Store records in a secure and accessible manner for auditing purposes.
Establish retention periods for records in accordance with regulatory requirements.

VIII. Compliance Monitoring and Auditing

Conduct regular internal audits and reviews of OFAC compliance procedures and controls.
Identify areas for improvement and corrective actions based on audit findings.
Monitor regulatory developments and update compliance practices accordingly.

IX. Reporting and Escalation

Establish procedures for reporting and escalating potential OFAC violations to management and regulatory authorities.
Ensure timely and accurate reporting of suspicious transactions or activities as required by law.
Cooperate with regulatory investigations and inquiries, if necessary.

X. External Resources

Stay informed about OFAC updates, guidance, and enforcement actions through official channels.
Seek guidance from legal counsel or compliance consultants for interpretation of OFAC regulations and compliance best practices.
Participate in industry forums and associations to exchange knowledge and best practices with peers.

XI. Signature

I, [YOUR NAME], hereby acknowledge that I have reviewed and understand the contents of this OFAC Compliance Checklist. I am committed to upholding the standards outlined herein and ensuring compliance with OFAC regulations at [YOUR COMPANY NAME].

[YOUR NAME]
Compliance Officer
[YOUR COMPANY NAME]
[YOUR COMPANY ADDRESS]

Date: