Part 2: OFAC Risk Assessment Methodology
By: Maleka Ali
Your company’s OFAC risk assessment is what drives your OFAC program’s policies and procedures and allows examiners to identify the strengths and weaknesses of your program.
- The FFIEC BSA/AML Exam Manual says that examiners may utilize a risk-based approach. However, OFAC’s enforcement standards remain a strict liability for violations, and executive orders are not risk-based.
- That being said, your OFAC program should be tempered by the Institution’s risk appetite and available resources to avoid both regulatory and OFAC violations.
- Your program’s policies and procedures must match or exceed the risk.