What must a credit union's OFAC program include?

A credit union's OFAC (Office of Foreign Assets Control) program must include establishing independent testing for compliance. This element is crucial because it ensures that the credit union is regularly evaluating the effectiveness of its procedures and controls related to compliance with OFAC regulations. Independent testing acts as a safeguard, allowing for an objective assessment outside of the usual operation processes.

By incorporating independent testing, a credit union can identify potential weaknesses or areas for improvement in its OFAC compliance program. This includes reviewing how well the credit union screens transactions and customers against OFAC's lists, assessing employee training programs on OFAC compliance, and verifying adherence to reporting requirements. This practice is fundamental to maintaining the integrity of the credit union’s operations and protecting it from risks associated with sanctions violations.

Other options mentioned do not directly align with the critical compliance aspects that OFAC requires. For instance, investment strategies, providing member financial advice, and creating promotional materials are not focused on ensuring compliance with legal requirements set by OFAC. Instead, OFAC programs must prioritize methods that help mitigate risks associated with financially supporting sanctioned individuals or entities.