Review a Bank’s OFAC program. I just need to complete part C and D – Description
I need a PP presentation and a Word document that will bring the information from the PP slides for me to present/read to my classmates. Please do not write in the PP slides the same information I will present in class just use bullet points with key words or phrases.
Please review links provided, this are important resources that will help you complete part C and D.
You are a consultant hired to review a Bank’s OFAC program. The Bank is expecting a comprehensive review that will identify both strengths and weaknesses in their OFAC program.
Additional Background about the Bank:
The Bank has a strong international presence, and offers many services, including international wires, online banking, pouch activity, and letters of credit.
Prepare in advance and present a detailed description of your plan for review of the bank’s OFAC program. In this planning document, you should document:
(a) the tasks you will perform to identify all OFAC systems at the bank
(b) how you will test each system to determine if it is updated
(c) the people with whom you will need to interview at the bank (in this section aside from writing who you will interview at the bank you need to write or elaborate as of why you are interviewing that person)
(d) key questions to anticipate asking bank management as you perform your review (e.g. anticipated growth, products to be offered, etc.) 3-4 questions are enough, you also need to answer why you will ask those question)
I recommend that you review the OFAC Framework for OFAC Compliance Commitments and try to incorporate it into your presentation. As we covered in class, this framework guidance describes what OFAC considers as the five essential components of a sanctions compliance program: (1) management commitment; (2) risk assessment; (3) internal controls; (4) testing and auditing; and (5) training. Given that your project is ultimately about evaluating the OFAC program of an international bank, I’m looking for your plan to address how you will evaluate each of these components.
a. You may also find the materials in the FFIEC Exam Manual I sent you previously relating to OFAC also helpful, including the Examination Procedures described in the manual that provide examiners guidance on how to examine Bank compliance with OFAC.
FFIEC BSA/AML Examination Manual
Office of Foreign Assets Control—Overview
Appendix J – Quantity of Risk Matrix
Appendix M – Quantity of Risk Matrix – OFAC Procedures
BSA/AML Risk Assessment
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