This policy is to assure this Credit Union's compliance with the Department of the Treasury, Office of Foreign Assets Control (OFAC) laws and regulations.

1. To identify by comparison to the OFAC SDN List, the name of any entity or individual that may be a member, co-maker, or joint owner on any account in this Credit Union.

2. To make this comparison on a recurring basis by matching the names in the Credit Union's database to the most current OFAC SDN (Specially Designated Nationals and Blocked Persons) List.

3. To monitor all financial transactions performed by this Credit Union for the purpose of detecting those transactions that involve any entity or person subject to the OFAC laws and regulations.

4. To verify that a "true match" exists in the event of a possible match.

5. To block withdrawals from an account with a true match (in a few cases, the deposit transaction may be blocked also).

6. To report true matches and blocked accounts to the OFAC.

1. Database Scrub.

1. On a monthly basis, the Credit Union's main data processing vendor (CUSA) will access the main database to retrieve a copy of the Name, Co-maker and Joint Owner files.

2. CUSA will compare the names in these files to the latest version of the OFAC SDN list.

2. New entity/individual check.

1. Credit Union employees will document any new entity/individual name that is added to a new or existing account. The Credit Union will maintain this list showing the new name and associated account number(s).

2. New names added to this list will be checked via the Internet to the OFAC current SDN listing. A printout, per each name, of the results of the computer search will be retained as evidence of this check.

1. All reports regarding the OFAC will be retained by the Credit Union for at least 5 years. An OFAC Binder will contain all reports.

2. Reports to the Credit Union from CUSA.

1. Within 72 hours of the monthly database scrub, CUSA will fax to the Credit Union an OFAC Processing Confirmation. CUSA will also fax an OFAC Results Report listing "possible matches" that were found.

2. Any possible matches listed on the report will be reexamined by a Credit Union employee. The employee will determine if the name is a "false-positive" match or a "true-positive" match.

3. False-positive matches will be so noted; true-positive matches will be reported to OFAC by management.

3. Reports/documents generated by the Credit Union.

1. OFAC New Name List: the Credit Union's Membership Officer will maintain this list. Any new names added to Credit Union records (joint owner, co-maker, beneficiary, etc.) will be entered on this list for immediate comparison to the SDN list.

2. OFAC Tracker Search Results: This "proof of search" from the Internet will be retained for each name on the OFAC New Name List.

3. Report of Blocked Transactions. This report must be submitted to OFAC within ten business days of any true-positive transaction.

4. Report of Rejected Transactions.

5. Annual Report of Blocked Property. This report is as of June 30^th of each year and must be reported to OFAC by September 30^th of that same year.

6. Application for the Release of Blocked Funds.

7. Cuban Remittance Affidavit.

1. Management will verify that a true positive identification has been made.

2. Management will consult with legal council prior to submitting a Blocked Account Report to the OFAC on any true positive account.

3. True positive deposit accounts will be blocked from any withdrawal activity. Management will establish a procedure to assure that no assets are disbursed to SDN List individuals or entities. In certain cases, the Credit Union may refuse to accept a check for deposit or for cash.

4. Management will submit an Application for the Release of Blocked Funds to the OFAC if and when appropriate.

1. Office of Foreign Assets Control (OFAC).
1. Compliance Hotline: 1-800-540-6322
2. Website: www.ustreas.gov/ofac
3. Mailing Address:
Office of Foreign Assets Control
U. S. Department of the Treasury
Treasury Annex
1500 Pennsylvania Avenue, NW
Washington, DC 20220
2. CUSA
1. Customer Relations (Resource Group): 1-800-825-2872
2. Website: www.cusa.com
Click on Clients, type in user name and password, click on OFAC Information, type in search name information.