Based on the OFAC Enforcement Guidance, what should the BSA Officer do FIRST to attempt to mitigate any penalties?

Last Updated on January 26, 2022 by Admin 2

The BSA officer has just been notified by the chief operations officer that, due to a glitch in the bank’s OFAC interdiction software, wires have been regularly transmitted to a bank on the SDN list. Based on the OFAC Enforcement Guidance, what should the BSA Officer do FIRST to attempt to mitigate any penalties?

  • Review the OFAC wire policies and procedures to determine how the errors occurred
  • Stop and hold all wires to the bank on the SDN list
  • Investigate the customer who sends these wires
  • Self-report the activity to OFAC
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