OFAC examinations assess your compliance program. Being prepared means having documentation and evidence of screening.
| Document | Why |
|---|---|
| Risk assessment | Verify you understand your exposure |
| Compliance policy | Verify documented procedures exist |
| Screening records | Evidence all customers/transactions screened |
| Training records | Evidence staff are trained |
| Audit reports | Evidence of independent review |
| Violation history | How violations were handled |
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.
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