Part 5: OFAC Independent Audits and Evaluations
By: Maleka Ali
Probably the best control an organization has in its OFAC controls arsenal is an OFAC scanning system. However, some organizations have been criticized for being too reliant on those systems when they weren’t working properly. So, in order to list them as a control, you must ensure they are working properly.
Manual or Automated
That being said, regulations don’t say everyone and everything must be automated. It says manual or automated.
There may be certain transactions, say, for example, new employees, that your procedures/processes are to check these manually, and that may be sufficient for the volume and the risk. However, scanning your entire database of customers every time there is an OFAC update is not something you could easily do manually. Whatever processes you use, you will have to justify that they are sufficient for catching transactions that are in violation of OFAC.