OFAC Sanctions Compliance

OFAC Sanctions Compliance. This institution shall maintain a comprehensive sanctions compliance program in accordance with the regulations administered by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury. The institution shall screen all customers, transactions, and counterparties against the OFAC Specially Designated Nationals and Blocked Persons (SDN) List, the Consolidated Sanctions List, and all applicable country-based and program-based sanctions. Screening shall be conducted: (a) at the time of account opening or customer onboarding; (b) upon receipt of incoming wire transfers and before processing outgoing wire transfers; (c) when processing trade finance or letter of credit transactions; (d) upon any update to the OFAC sanctions lists; and (e) at such other intervals as risk-based procedures may require. All potential matches (hits) shall be investigated and resolved by trained compliance personnel. Confirmed matches shall be reported to OFAC, the associated funds or property shall be blocked or rejected as required, and a report shall be filed within ten (10) business days. The institution shall maintain all records related to blocked or rejected transactions for a minimum of five (5) years.