Compliance Programs

While OFAC has no authority to require financial institution compliance programs, it does strongly recommend them:

: It is suggested that every bank designate a Compliance Officer responsible for monitoring compliance with its programs and an officer responsible for overseeing blocked funds. Formal compliance responsibilities may also be assigned to all operations and systems managers. Internal auditing departments could be charged with assisting in the development of “corporate compliance memoranda” and verifying that procedures, once established, are being followed….; An in-depth audit of each department in the bank should probably be conducted at least once a year. The compliance audit may either be incorporated into a bank’s standard auditing program or conducted separately….; An effective internal communication network is critical for regulatory compliance. Banks might consider including regulatory notices and explanations in staff newsletters. Compliance training programs ought to be initiated—reviewing regulations in staff meetings, incorporating compliance requirements into operating procedures, and joining with other banks to sponsor seminars.

(Foreign Assets Control Regulations for the Financial Community, p. 3, OFAC, February 16, 2007)