Besides designating an OFAC compliance officer, what is another requirement for an OFAC compliance program?

• A. Conduct a full internal audit of all customer accounts
• B. Implement appropriate training in OFAC compliance
• C. Publish a list of sanctioned individuals to customers
• D. Hire external investigators for all transactions

Answer: (B)

Training staff in OFAC compliance is a foundational element of an effective sanctions program. Beyond naming an OFAC compliance officer, organizations must ensure that those handling customers, payments, and transactions understand how to recognize and respond to potential sanctions issues. Ongoing, role-appropriate training covers how to use sanctions lists, how to screen transactions and counterparties, what constitutes a potential match, and the escalation and reporting steps to take when a match is suspected. This education builds consistent, informed decision-making across the organization and helps prevent inadvertent violations, which is the core purpose of having a formal OFAC program.

Other options do not align with OFAC requirements. Conducting a full internal audit of all customer accounts is a broader AML control, not a specific OFAC program mandate. Publishing a list of sanctioned individuals to customers is not required and could raise privacy or operational concerns. Hiring external investigators for all transactions is unnecessary and not mandated as part of OFAC compliance.