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Question 441 - CRCM discussion
The BSA officer has just been notified by the chief operations officer that, due to a glitch in the bank's OFAC interdiction software, wires have been regularly transmitted to a bank on the SDN list. Based on the OFAC Enforcement Guidance, what should the BSA Officer do FIRST to attempt to mitigate any penalties?
A.
Review the OFAC wire policies and procedures to determine how the errors occurred
B.
Stop and hold all wires to the bank on the SDN list
C.
Investigate the customer who sends these wires
D.
Self-report the activity to OFAC
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