Extract to table

To the extent any previously existing procedure conflicts with the provisions of this Manual, the provisions of this Manual shall control

Blocked property must be segregated and may not be released, transferred, or otherwise dealt in without specific authorization (license) from OFAC

Transaction Monitoring System ("Veridian TMS"), must incorporate all OFAC list updates within 24 hours of publication by OFAC

Verification must be performed daily and must include the following steps: 1

A comprehensive log of all list updates, including the date and time of OFAC publication, the date and time of ingestion into the Veridian system, the list version number, the record count, and the identity of the OFAC Screening Unit analyst who performed the verification, must be maintained in the OFAC screening system and archived for a minimum of five years from the date of each entry

Additions to and removals from the internal watchlist must be documented with a supporting rationale and approved by a Senior OFAC Analyst