Which of the following is NOT a required part of the OFAC program?

The correct response, indicating that recording customer complaints is not a required part of the Office of Foreign Assets Control (OFAC) program, is based on the specific mandates outlined in the regulations governing OFAC compliance.

An effective OFAC program focuses on risk management related to sanctions and ensuring that financial institutions can conduct their operations without encountering entities or individuals that are subject to U.S. sanctions. Key components of a robust OFAC program typically include:

• Identifying high-risk areas, which helps institutions understand where their exposure to violations may be highest, allowing for proactive risk mitigation.

• Providing internal controls for screening purposes, which involves implementing procedures to vet customers and transactions against OFAC’s lists of sanctioned individuals and entities.

• Developing training programs for personnel who interact with compliance obligations ensures that employees are adequately equipped to recognize and respond to potential OFAC violations.

In contrast, while managing customer complaints may be important for customer service and overall business operations, it does not specifically align with the core objectives of an OFAC compliance program, which centers around sanctions enforcement and risk management. Consequently, it is not considered a mandatory element within the framework of OFAC requirements.