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More resources for national banks

Counter Terrorist Financing

Identifying terrorist financing can be challenging for OCC banks. Meeting the following objectives can greatly enhance a bank’s ability to achieve this goal.

  • Conducting a complete risk assessment and developing a thorough understanding of the AML/CFT risks not only within lines of businesses, but across the bank. Understanding the inherent risks in product and service offerings as well as how these are used by customers is important.

  • Establishing an effective BSA compliance and transaction monitoring program based on the bank’s risk profile.  This is a key step in reporting all suspicious and unusual activity that may indicate potential terrorist financing activity to assist law enforcement to analyze and follow up on reported activity.

  • Screening for potential OFAC violations and effectively reviewing and closing alerts generated in a timely manner.

Additional Guidance is also available from the following sources: