Certified Regulatory Compliance Manager (CRCM) — Question 244

Your bank's president comes back from an industry conference and tells the compliance officer that she attended a presentation about OFAC. She heard the bank could be fined for not adhering to OFAC requirements. Thus, she has directed that every bank transaction be reviewed for OFAC compliance. What is the most appropriate statement the compliance officer could make to the bank president?

Answer options

• A. The bank is already in compliance because OFAC checks are performed on all new depositors
• B. The bank has assessed its OFAC risk and has implemented risk-based OFAC procedures
• C. OFAC does not apply because the bank does not conduct business in foreign countries or with foreign nationals
• D. Banks are usually not fined for OFAC violations unless they conduct transactions with SDNs or blocked countries

Correct answer: B

Explanation

The correct answer is B because it indicates that the bank has proactively assessed its OFAC risks and put in place appropriate procedures, showcasing due diligence. Option A is incorrect as it focuses only on new depositors and does not address overall compliance. Option C is wrong because OFAC regulations can apply regardless of whether the bank deals with foreign entities. Option D is misleading; while fines may be more likely in certain situations, banks can still be penalized for non-compliance in other scenarios.