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?
The bank should have risk-based procedures for OFAC compliance that are appropriate for its specific risk profile. Therefore, the most appropriate statement the compliance officer could make is to inform the president that the bank has already assessed its OFAC risk and implemented procedures based on that risk assessment. This ensures that the bank's OFAC compliance measures are efficient and effective without being overly burdensome.
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