By SanctionsAI team · Updated 2026-08-09

How to prepare for an OFAC compliance examination

OFAC examinations assess your compliance program. Being prepared means having documentation and evidence of screening.

What examiners request

DocumentWhy
Risk assessmentVerify you understand your exposure
Compliance policyVerify documented procedures exist
Screening recordsEvidence all customers/transactions screened
Training recordsEvidence staff are trained
Audit reportsEvidence of independent review
Violation historyHow violations were handled

Preparation checklist

1. Update risk assessment (current within 12 months). 2. Verify screening coverage (ALL customers and transactions). 3. Test audit trail (can you produce records for any date?). 4. Review training completion (100%). 5. Remediate known gaps. 6. Prepare compliance program overview.

Pro tip: Conduct mock examinations annually. Simulate the OFAC document request to identify gaps before the real thing.

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Frequently Asked Questions

How often are OFAC examinations conducted?
For banks: every 12-18 months. Non-banks: varies by risk profile.
What documents do I need?
Risk assessment, compliance policy, screening records, training records, audit reports, governance structure.
What are common findings?
Inadequate risk assessments, screening gaps, stale training, missing audit trails.
How should I handle findings?
Accept, develop remediation plan with timelines, document implementation.

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