Extract to table

OFAC's guidance makes clear that a screening program must be designed to ensure that all transactions are screened before they are processed and that screening must be conducted on a real-time or near-real-time basis for high-risk transaction types

Although these partners' lower transaction volumes result in smaller absolute numbers of unscreened transactions, the existence of any screening bypass in a BaaS partner channel is a deficiency that must be remediated

BRB's screening system must incorporate all relevant OFAC lists and must be updated promptly when OFAC publishes new designations, amendments, or de-listings

When the screening system identifies a true match to an OFAC sanctions list entry, BRB must take prompt action to block the transaction (for SDN matches and other programs requiring blocking) or reject the transaction (for programs requiring rejection rather than blocking), and must file appropriate reports with OFAC

Blocking and Rejecting Protocols When a true OFAC match is identified, BRB is required to take immediate action

For transactions involving persons on the SDN List, BRB must block the transaction and freeze the property in an interest-bearing blocked account