Regulator-Readiness Checklist
The quarterly drill that makes an OFAC inquiry a 10-minute export.
How to use
How to use: run quarterly. The goal is that an OFAC inquiry is answered with exports, not archaeology.
Evidence
- Screening logs exportable with list versions
- Payment records paired with screen results
- Timestamp chain proving screen-before-sign
- Blocked/flagged results with review decisions
Program
- Documented five-pillar compliance program
- Risk assessment on file (scored, dated)
- Training records for relevant staff
- Compliance owner designated
Controls
- Fail-closed behavior tested
- List freshness verified (hourly sync)
- No agent override path exists
- Alerts reach a human
Why this exists
OFAC asks for the audit trail first. The checklist converts an inquiry from a project into an export.