ANSWERS 100% CORRECT!!
Credit unions must report blocked or rejected transactions within __________ business
days from the date that property becomes blocked or the transaction is rejected.
a. 14 business days
b. 30 calendar days
c. 10 business days
d. The date that the property is blocked/transaction is rejected. - ANSWERTHE
CORRECT ANSWER IS C
Blocked and rejected transactions must be reported to OFAC within 10 business days
from the date that property becomes blocked or the transaction is rejected.
True or false. All financial institutions must file an annual report of blocked property. -
ANSWERFALSE
All holders of blocked property must file a comprehensive annual report on blocked
property held as of June 30 by September 30 each year. There's no need to file the
annual report if the credit union isn't holding any blocked property.
What should the credit union do with blocked property (i.e., funds in an account)?
a. Remit the blocked funds to OFAC
b. Place blocked funds into an interest-bearing account on the institution's books
c. Report blocked funds on a suspicious activity report
d. Monitor to ensure member doesn't conduct transactions - ANSWERTHE CORRECT
ANSWER IS B
Credit unions should place blocked funds into an interest-bearing account on your
books; only OFAC-authorized debits may be made.
OFAC record retention requires which of the following:
a. Records of rejected items must be maintained for 5 years from the date of the
transaction.
, b. Records of blocked accounts must be maintained for 5 years after the date that the
account is unblocked.
c. Credit unions are required to maintain a complete and accurate record of the blocked
account for as long as it's holding the blocked property.
d. All of the above. - ANSWERTHE CORRECT ANSWER IS D
All OFAC records must be retained for 5 years: • Rejected items: maintain records for 5
years from the date of the transaction. • Blocked accounts: maintain records for 5 years
after the date that the account is unblocked. • Maintain a complete and accurate record
of the blocked account for as long as the credit union is holding the blocked property.
NCUA and the state regulators will expect a credit union to establish and maintain an
effective, written OFAC compliance program that reflects the institution's OFAC "risk
profile." The program should:
a. Designate an OFAC compliance officer
b. Identify high-risk areas and provide for appropriate internal controls
c. Train appropriate personnel and ensure independent testing for compliance
d. All of the above - ANSWERTHE CORRECT ANSWER IS D
• Designate an OFAC compliance officer: every credit union must designate a qualified
individual(s) to be responsible for the day-to-day compliance with OFAC requirements,
including keeping track of updates to the various sanctions' programs, reporting blocked
or rejected transactions to OFAC, and overseeing blocked funds.
• Identify high-risk areas: this means assessing your credit union's membership, product
lines, and nature of the transactions that flow through your institution and identifying the
higher-risk areas for potential OFAC sanctions risk.
• Provide for appropriate internal controls for screening accounts and transactions,
updating OFAC lists (whether manually or using interdiction software), blocking and
rejecting prohibited transactions, and reporting OFAC matches or "hits."
• Establish independent testing for compliance: every credit union should conduct an
independent test of its OFAC compliance program that is performed by the internal audit
department, outside auditors, consultants, or other qualified independent parties.
• Create training programs on the credit union's OFAC compliance procedures and
processes for appropriate personnel in all relevant areas of the institution. The scope