Should ABC LLC update its AML procedures and software to include the OFAC list?

Meet Mr. A, the newly appointed compliance officer at ABC LLC in Dubai.

He’s been tasked with revamping the company’s AML/CFT program to meet regulatory standards and recent business changes.

While conducting a gap analysis, Mr. A discovered that ABC LLC has recently started dealing with US-based clients, which involves cross-border fund transfers.

The company’s sanctions screening procedures only cover the UAE’s local sanctions list and the UN Security Council list.

The AML software in place also supports only these two lists.

Should Mr A recommend that ABC LLC update both its sanctions screening procedures and software to include the OFAC list?

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  • Yes
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