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    How frequently is an insurer expected to scrub its databases for OFAC compliance?

    That is up to your firm and your regulator. Remember that a critical aspect of the designation of an SDN is that the SDN's assets must be frozen immediately, before they can be removed from U.S. jurisdiction. If a firm only scrubs its database quarterly, it could be 3 months too late in freezing targeted assets. The SDN list may be updated as frequently as a few times a week or as rarely as once in six months.

    Office of Foreign Assets Control (OFAC), U.S. Treasury Department
    http://www.treas.gov/offices/enforcement/ofac/


 
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