Control Considerations For Auditing the OFAC Affidavit Program
Author: Cheryl Sincock, CAMS-Audit
OFAC generally prohibits financial institutions from processing transactions involving sanctioned countries unless exempted by a specific regulatory provision. One provision is for the processing of certain transfers to or from sanctioned countries that represent non-commercial personal remittances.
The intent of this paper is to look at transactions that may be exempted from U.S. Treasury’s Sanctions and the controls that a bank should establish to mitigate risk of non-compliance with OFAC sanction regulations.