Association of International Bank Auditors (AIBA)OFAC Survey – July 2012

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Association of International Bank Auditors (AIBA)OFAC Survey – July 2012

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Association of International Bank Auditors (AIBA)OFAC Survey – July 2012

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Association of International Bank Auditors (AIBA)OFAC Survey – July 2012

Daniel Patrick Moynihan famously said, “Everyone is entitled to their own opinion but not their own facts…..” Well, here are mine anyway:

•Smaller financial institutions with up to 50 staff members tend to:– Have a higher % of false positives particularly when they process smaller number of transactions per day (up to 100

or up to 500 per day)– Higher inclination of using integrated/shared processes– Conduct manual OFAC checks of trade-related documents whether in international or domestic– Have a centralized point of contact and internal escalation process

•Medium-sized financial institutions of 51-200 staff members tend to:– Have higher % of false positives when they process smaller volumes compared to higher volumes– Have integrated/shared processes– Does not have a centralized point of contact or internal escalation when there are less processed transactions– Perform manual OFAC checks of trade-related docs

•Larger financial institution of more than 500 staff members tend to:– Higher % of false positives with higher transactions– Have integrated/shared processes as they process more transactions– Have centralized point of contact– Have internal escalation process– Perform manual OFAC for larger transactions per day

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