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?
The correct action for the BSA Officer to take first, based on OFAC Enforcement Guidance, is to self-report the activity to OFAC. Self-reporting the violation to OFAC can demonstrate the financial institution's commitment to compliance and transparency, which can help mitigate any potential penalties. While stopping and holding all wires to the SDN-listed bank is also important, it is a subsequent step that follows notifying OFAC about the issue.
B is correct