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.

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