OFAC Compliance Checklist
OFAC Compliance Checklist
I. Compliance Program Overview
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Company Commitment: Declare [YOUR COMPANY NAME]'s commitment to OFAC compliance.
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Responsible Party:[YOUR NAME], [YOUR DEPARTMENT]
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Date of Last Review: [DATE]
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Next Scheduled Review: [DATE]
II. Risk Assessment
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Conduct an extensive risk assessment to identify potential exposure to sanctioned parties and countries.
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Assess business actions, locations, and customers to identify risks.
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Document risk assessment findings and establish risk mitigation strategies.
III. Screening Procedures
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Screen customers, vendors, and business partners using robust procedures against OFAC's SDN list.
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Utilize automated screening tools and software to enhance efficiency and accuracy.
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Conduct periodic screenings and update screening procedures as necessary.
IV. Transaction Monitoring
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Establish transaction monitoring systems to detect and flag suspicious transactions or activities.
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Define thresholds and criteria for triggering alerts and conducting further investigation.
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Train staff members responsible for transaction monitoring on identifying red flags and reporting procedures.
V. Due Diligence
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Conduct due diligence on new customers, vendors, and partners to prevent illegal transactions.
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Verify the identity and background of counterparties through reliable sources.
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Document due diligence efforts and maintain records for audit purposes.
VI. Employee Training
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Provide comprehensive training to employees on OFAC regulations, policies, and procedures.
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Offer regular refresher training sessions to reinforce key concepts and updates.
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Encourage employees to report any potential compliance concerns or issues promptly.
VII. Record-keeping
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Maintain accurate records of OFAC compliance efforts, including screening results, due diligence documentation, and training records.
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Store records in a secure and accessible manner for auditing purposes.
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Establish retention periods for records in accordance with regulatory requirements.
VIII. Compliance Monitoring and Auditing
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Conduct regular internal audits and reviews of OFAC compliance procedures and controls.
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Identify areas for improvement and corrective actions based on audit findings.
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Monitor regulatory developments and update compliance practices accordingly.
IX. Reporting and Escalation
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Establish procedures for reporting and escalating potential OFAC violations to management and regulatory authorities.
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Ensure timely and accurate reporting of suspicious transactions or activities as required by law.
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Cooperate with regulatory investigations and inquiries, if necessary.
X. External Resources
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Stay informed about OFAC updates, guidance, and enforcement actions through official channels.
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Seek guidance from legal counsel or compliance consultants for interpretation of OFAC regulations and compliance best practices.
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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:
