Scenario: Responding to an OFAC Inquiry
The OFAC inquiry scenario - what they ask, what you produce, and the drill that makes it painless.
The setup
OFAC sends an information request about transactions involving your agent - typically a subpoena or voluntary request letter with a deadline.
What they ask for
- Transaction records involving the named parties
- Screening results for those transactions
- Your compliance program documentation
- Policies, procedures, and training records
What you produce
- Screening logs: every check, result, list version, timestamp
- Payment records paired with screen results
- Your documented program (the five pillars)
- A timeline of remediation
The drill
If you screen before sign and log every result, the response is assembled in minutes. If you cannot produce the audit trail, the inquiry is already going badly.