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communication between departments of the bank, employee training, and an annual in-depth audit of OFAC compliance. The compliance program should also include procedures for maintaining current lists of blocked countries, entities, and persons and for disseminating such information throughout the bank’s domestic operations and its offshore branches and offices. All new accounts, including deposit, loan, trust, or other relationships must be compared with the OFAC lists when accounts are opened. Established accounts should be compared regularly with the current and updated OFAC lists. Wire transfers, letters of credit, and non-customer transactions, such as funds transfers, should be compared with the OFAC lists before being conducted.

Federal law enforcement may request information about suspected terrorists and money launderers relevant to investigations. Bankers must review their records for accounts and transactions and notify the Financial Crimes Enforcement Network (FinCEN) of any “matches” in accordance with the instructions provided.

Establish an Effective Suspicious Activity Monitoring and Reporting Process

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"If you place one seed of truth on a particular side of the cosmic scale, it can sway the entire balance of power in a new direction". - Dr. Jur. George Mentz Editor of the Magazine of Wall Street Est. 1907 www.magazineofwallstreet.com

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