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Does OFAC itself require that banks set up a certain type of compliance program?
No. There is no single compliance program suitable for every financial institution. OFAC is not itself a bank regulator; its basic requirement is that financial institutions not violate the laws that it administers. Financial institutions should check with their regulators regarding the suitability of specific programs to their unique situations.
Office of Foreign Assets Control (OFAC), U.S. Treasury Department
http://www.treas.gov/offices/enforcement/ofac/
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