With 2015 on the horizon, it’s a great time to reflect on the past year and evaluate your organization’s OFAC compliance highs and lows. How satisfied are you with your OFAC compliance program? Is there room for change in the New Year? Here are 5 resolutions that could make life easier (and more compliant) in 2015:
Resolution #1: Commit to OFAC Compliance Efficiency
Nobody sets out to be inefficient, but your current OFAC compliance processes may be just that. Are you doing things because “that’s how they’ve always been done”? Does your staff complain that their work takes too long, or that tasks require the burdensome involvement of too many people? Take another look at the way your team handles its OFAC screening obligations. If these activities aren’t being completed in (a) the least amount of time possible and (b) using the fewest company resources possible, it may be time to look at some new solutions. Saving time, money, and employee morale will be worth it.
Resolution #2: Realize the Reach of OFAC Screening
OFAC Screening is essential to maintaining solid compliance, but not everyone realizes what’s available to them in terms of screening options. Maybe your company is screening one name at a time at the point of transaction, but your growing customer or transaction volume suggests it’s time to consider batch screening. Perhaps you’re a prime candidate for integrated screening but you’re still devoting significant time each day to ensuring your screening’s getting done. A lot can change in your business in the course of a year. Is the way you screened last year still working for you?
Resolution #3: Centralize Your OFAC and Corporate Screening Data
To say your screening data is valuable is a bit of an understatement. You need it for your export and financial transactions, you need it for audit purposes – it’s absolutely vital to keeping your company running – especially when you want to include corporate lists of competitors and other proprietary exclusions. That’s why the way you access it is pretty darned important. Suppose Mary from your Houston division can’t access the screening information she needs because Rob from your Portland office is on vacation and nobody can find his files. Contacting Rob on a beach in Aruba may be your only course of action (assuming Rob picks up his phone), but a centralized system that facilitates information-sharing is a more efficient, reliable and consistent way of doing things. When everyone can get what they need when they need it, the likelihood of dropping the compliance ball is significantly lessened.
Resolution #4: Prioritize Professional Development
If your team is running like a well-oiled machine it’s easy to adopt the attitude of “if it ain’t broke, don’t fix it”. But professional development is key to keeping your compliance program running smoothly. Never assume that refresher training in your compliance software isn’t necessary, or that key personnel are up-to-speed on all new regulations. Keep your team informed and active: Hold regular meetings to generate fresh ideas, subscribe to compliance blogs, participate in online industry forums, even send people to conferences. Networking and sharing best practices will help make your team stronger, more knowledgeable and more engaged in their work. What could be better than that?
Resolution #5: Review your Recordkeeping
We all know that the government could come knocking tomorrow. So why do some of us procrastinate when it comes to getting our records in order? You need to be able to account for the past five years of your OFAC compliance activities and decision-making. If you’re working solely with paper records stuffed into filing cabinets, or spreadsheets that are stored on the computer of “that guy on the third floor…wait, didn’t he retire last year?” then 2015 is the year for you to examine your audit-readiness. How detailed and comprehensive are your records? How much time and effort does it currently take you to build and maintain them? Is this the year you invest in an automated system to ensure you can prove your due diligence?
No matter what challenges the New Year brings, being realistic about the strengths and weaknesses of your OFAC compliance program is essential. What’s first on your resolutions list?