Examiners should use the following matrix, as appropriate, when assessing a bank’s risk of encountering an OFAC issue.

Low Moderate High

Stable, well-known customer base in a localized environment.

Customer base changing due to branching, merger, or acquisition in the domestic market.  

A large, fluctuating client base in an international environment.

Few higher-risk customers; these may include nonresident aliens, foreign individuals (including accounts with U.S. powers of attorney), and foreign commercial customers.  

A moderate number of higher-risk customers.

A large number of higher-risk customers.

No overseas branches and no correspondent accounts with foreign banks.  

Overseas branches or correspondent accounts with foreign banks.

Overseas branches or multiple correspondent accounts with foreign banks.

No electronic banking (e-banking) services offered, or products available are purely informational or nontransactional.

The bank offers limited e-banking products and services.

The bank offers a wide array of e-banking products and services (e.g., account transfers, e-bill payment, or accounts opened via the Internet).  

Limited number of funds transfers for customers and noncustomers, limited third-party transactions, and no international funds transfers.

A moderate number of funds transfers, mostly for customers.  Possibly, a few international funds transfers from personal or business accounts.  

A high number of customer and noncustomer funds transfers, including international funds transfers.

No other types of international transactions, such as trade finance, cross-border ACH, and management of sovereign debt.  

Limited other types of international transactions.

A high number of other types of international transactions.

No history of OFAC actions.  No evidence of apparent violation or circumstances that might lead to a violation.

A small number of recent actions (e.g., actions within the last five years) by OFAC, including notice letters, or civil money penalties, with evidence that the bank addressed the issues and is not at risk of similar violations in the future.

Multiple recent actions by OFAC, where the bank has not addressed the issues, thus leading to an increased risk of the bank undertaking similar violations in the future.


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Appendix N – Private Banking – Common Structure