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Banks remain a leading area of focus for compliance issues. All banking transactions
should be screened in order to avoid compliance violations. Areas such as new
accounts, wires, and letters of credit should be checked when the transactions
occur. The entire customer information file (CIF) should be rechecked whenever
compliance agencies update their master lists.
Where should a bank begin in implementing compliance systems? Begin by identifying the types of transactions which create the most risk for compliance violations. These areas typically include the following: wires, new accounts, letters of credit, loans, and CIF files. You may find the OFAC and USA PATRIOT Act Policy and Procedure Guides helpful for this. |
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