OFAC Investigations

• Reviewing internal/external referrals received by the Complex Investigations team to determine whether there is any potential sanctions nexus;
• Assisting in ad-hoc returned payment and complex post-hoc payment lookback reviews;
• Conducting transaction reviews as part of the BAU typology sampling process;
• Reviewing returned payments for sanctions nexus, and comparing with prior Voluntary Self Disclosures;
• Assisting in the drafting of typology parameters for Sanctions Intelligence Tool typologies, as needed;
• Documenting typology rationales, as needed;

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