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Date: March 28, 2016

United States Bank examiners are instructed in their work by an extensive “Examination Manual” issued by an umbrella U.S. government agency called the Federal Financial Institution Examination Council (FFIEC).

The FFIEC BSA/AML Examination Manual refers to sanctions compliance several times. It explains the requirements and regulations of the Office of Foreign Assets Control. The Manual begins by telling the examiners, at page 2, that, “While OFAC regulations are not part of the BSA, the core [examination] sections include overview and examination procedures for examining a bank’s policies, procedures, and processes for ensuring compliance with OFAC sanctions. As part of the scoping and planning procedures, examiners must review the bank’s OFAC risk assessment and independent testing to determine the extent to which a review of the bank’s OFAC compliance program should be conducted during the examination. Refer to core examination procedures, “Office of Foreign Assets Control,” page 152, for further guidance.”

More about the instructions the FFIEC Exam Manual gives to bank examiners in upcoming Sanctions Briefs. (March 28, 2016)