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:                               

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