Compliance with OFAC, AML, and USA Patriot Act Toolkit | Practical Law

Compliance with OFAC, AML, and USA Patriot Act Toolkit | Practical Law

Resources to assist financial institutions in complying with OFAC, anti-money laundering, and USA Patriot Act requirements.

Compliance with OFAC, AML, and USA Patriot Act Toolkit

Practical Law Toolkit 8-601-7665 (Approx. 6 pages)

Compliance with OFAC, AML, and USA Patriot Act Toolkit

by Practical Law Finance
Maintained • USA (National/Federal)
Resources to assist financial institutions in complying with OFAC, anti-money laundering, and USA Patriot Act requirements.
Financial institutions are under heightened scrutiny of financial institution compliance with applicable anti-money laundering (AML) and Office of Foreign Assets Control (OFAC) regulations.
They are subject to comprehensive AML and OFAC compliance program requirements, which require, among other things:
  • Internal controls.
  • Independent testing and auditing.
  • A dedicated compliance officer.
  • Ongoing employee training.
  • A customer identification program (CIP).
Institutions that are subject to regulatory actions, such as cease and desist orders or civil monetary penalties, are typically guilty of one or some of the following compliance program failures:
  • Failing to have a written program that adequately covers the required elements.
  • Failing to properly implement and maintain the program.
  • Defective programs allowing suspicious activity to go unreported.
  • Structuring transactions to avoid reporting requirements or cases of insider complicity.
  • Failing to file required Bank Secrecy Act reports, such as suspicious activity reports (SARs) or customer transaction reports.
Practical Law provides several know-how resources on AML and OFAC requirements for financial institutions, including: