Who is primarily responsible for OFAC compliance oversight?

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Multiple Choice

Who is primarily responsible for OFAC compliance oversight?

Ensuring sanctions compliance is led by the Compliance Officer. This person owns the sanctions program, keeping it current with OFAC rules and lists, and designing and implementing the processes that screen customers and transactions, flag potential matches, and trigger due diligence and escalation when needed. The Compliance Officer also trains staff, tests controls, and reports findings and remediation needs to senior management and, as required, the board or risk committee. The other roles support governance and controls but aren’t the primary owner of OFAC oversight: the Risk Committee provides board-level risk oversight, not day-to-day sanctions operations; the Internal Controls Manager focuses on the effectiveness of internal controls in general, not specifically sanctions compliance; and the Chief Financial Officer handles financial strategy and reporting, with sanctions compliance typically remaining within the compliance function.

Ensuring sanctions compliance is led by the Compliance Officer. This person owns the sanctions program, keeping it current with OFAC rules and lists, and designing and implementing the processes that screen customers and transactions, flag potential matches, and trigger due diligence and escalation when needed. The Compliance Officer also trains staff, tests controls, and reports findings and remediation needs to senior management and, as required, the board or risk committee.

The other roles support governance and controls but aren’t the primary owner of OFAC oversight: the Risk Committee provides board-level risk oversight, not day-to-day sanctions operations; the Internal Controls Manager focuses on the effectiveness of internal controls in general, not specifically sanctions compliance; and the Chief Financial Officer handles financial strategy and reporting, with sanctions compliance typically remaining within the compliance function.

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