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Music in this session we are going to be speaking with Nathan Behnke regulatory compliance advisor at Cornerstone Credit Union League and he's going to talk about the OFAC compliance requirements so first Nathan what is a FAQ sure oh fak stands for the office of foreign asset control both AK is a division of the US Treasury Department which administers and enforces economic and trade sanctions based on u.s. foreign policy and national security goals oh fak maintains a list of individuals that US citizens are prohibited to conduct transactions with all bank regulatory agencies and the National Credit Union Administration cooperate to ensure compliance with effec okay so speaking broadly what does a credit union need to be doing to be compliant with OFAC then every credit union is expected both by OFAC state regulators and the National Credit Younis tration to establish and maintain an effective written moffat compliance program appropriate to the credit unions risk profile the first step in OFAC compliance is developing an OFAC risk assessment appendix M - the FFIEC s bsa/aml examination manual is a great resource to get you started on your OFAC risk assessment a risk assessment should consider all of the credit unions operations this includes the type of transactions and transaction parties resources both staff and technology and the geographic risks to areas that are serviced by the credit union a good way to frame effect compliance is to ask which areas of the credit unions operations create the most risk for an effect violation and how will we work to mitigate that risk so for example wire transfers and foreign transactions do you mean yeah sure Sam those are a given we're also talking about opening new accounts payments to non-members and beneficiaries a credit union should also look at other areas to determine risk such as the kinds of products and services the credit union offers the field of membership the number of members asset size and the credit unions general geography and branch locations who must comply with the ofat guidelines then all US citizens businesses and financial institutions operating under US jurisdiction Moffat covers everyone everyone has a duty to prevent block or freeze transactions against those OFAC designates as prohibited parties how does a credit union fulfill its duties with regard to OFAC first by creating an effect policy the policy needs to be approved by the board and be in line with the credit unions risk this policy needs be reviewed on a regular basis and at least once a year similar to the BSA compliance program the credit unions effect compliance program needs to identify high-risk areas such as wires cross-border ACH transactions and other sorts of transactions prfor appropriate internal controls for screening and reporting establish independent testing for compliance designate and employee or employees as responsible for OFAC compliance and create training programs for appropriate personnel in all relevant areas of the credit union how does a.