ACME Bank is a $600 million institution with 15 branches within three counties. Because of its proximity to Mexico, the bank has many foreign national customers and makes many foreign wire transfers for its customers. Currently the bank's branch managers print the OFAC list of SDNs and place them in strategic places in each branch. The wire transfer department keeps its own copy of the list. The compliance officer has implemented an annual auditing program to check the bank's compliance with OFAC regulations. The findings of this audit are provided to the bank's board of directors annually. The bank's regulatory agency has indicated to management that the bank has a high risk for BSA/AML/OFAC compliance. Of the following actions, which would be the most effective to strengthen the bank's OFAC compliance?
- Conduct compliance audits twice a year
- Purchase and implement interdiction software for the wire transfer area
- As an internal control procedure, require the BSA officer to check the OFAC Web site daily for any changes to the SDN list
- Routinely provide account transaction information to federal security agencies so suspicious patterns can be detected
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