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Fincen training courses Form: What You Should Know

Financial Crimes Enforcement Network (Fin CEN)” This material may be reproduced and distributed only with permission of the Financial Crimes Enforcement Network/Office of Terrorism and Financial Intelligence. Use of this publication constitutes acceptance of the terms of use and applicable privacy policy.

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Music in this session, we are going to be speaking with Nathan Behnke, a regulatory compliance advisor at Cornerstone Credit Union League. He's going to talk about the OFAC compliance requirements. So first, Nathan, what is FAQ? Sure, FAQ stands for the Office of Foreign Asset Control (OFAC). OFAC is a division of the US Treasury Department, which administers and enforces economic and trade sanctions based on US foreign policy and national security goals. OFAC 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 OFAC. Speaking broadly, what does a credit union need to do to be compliant with OFAC? Every credit union is expected, by OFAC, state regulators, and the National Credit Union Administration, to establish and maintain an effective written OFAC compliance program appropriate to the credit union's risk profile. The first step in OFAC compliance is developing an OFAC risk assessment. Appendix M of 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 union's 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 OFAC compliance is to ask which areas of the credit union's operations create the most risk for an OFAC violation and how will we work to mitigate that risk. So, for example, wire transfers and foreign transactions? Yes, 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...