Update on current OFAC Screening Requirements and How to Improve the Screening Processes as part of your overall Customer Due Diligence Program.
For more information about this topic, please contact SHAUN HASSETT at due_diligence@att.net
Customer Due Diligence: Improving Screening Processes for OFAC Entities and Other High Risks
1. Customer Due Diligence: How to bring clarity to screening for OFAC Sanctioned Entities and other High-Risk Entities April 7, 2009 Shaun M. Hassett, CAMS National Risk Specialist Clarity Risk & Compliance Advisors
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9. OFAC Overview Country-Based Programs Cuba, Iran, Sudan Regime-Based Programs Burma Belarus, North Korea, Iraq I and Iraq II Liberia (former regime ) List Based Programs Narcotics Trafficking, Diamond Trading, Anti-Terrorism, WMD, Balkans, Syria, Lebanon, Congo, Ivory Coast, Zimbabwe Sanctions Program Categories
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18. Voluntary Self-Disclosure Egregious Case (1) One-Half Transaction Value ($125k Cap) No Yes No Yes (3) One-Half Statutory Maximum (2) Applicable Schedule Amount ($250k Cap) (4) Statutory Maximum Base Penalty Calculation OFAC Enforcement Guidelines
47. The cover payment Ordering customer’s bank Beneficiary Bank Sender’s USD Correspondent MT 202 Receiver's USD Correspondent CHIPS/Fed MT 910/950 Ordering Customer Beneficiary * Example in USD Also valid for other currencies that apply cover (mainly GBP) MT 103 in USD*
48. The issue MT 103 in USD Ordering customer’s bank Bene’s bank Sender’s USD Correspondent MT 202 Receiver's USD Correspondent CHIPS/Fed MT 910/950 Ordering Customer UNKNOWN PARTIES IN THE COVER PAYMENT Beneficiary