Association of International Bank Auditors (AIBA) OFAC Survey – July 2012

1. Association of International Bank Auditors (AIBA)OFAC Survey – July 2012 RESTRICTED

2. Association of International Bank Auditors (AIBA)OFAC Survey – July 2012 RESTRICTED

3. Association of International Bank Auditors (AIBA)OFAC Survey – July 2012 RESTRICTED

4. Association of International Bank Auditors (AIBA)OFAC Survey – July 2012 Daniel Patrick Moynihan famously said, “Everyone is entitled to their own opinion but not their own facts…..” Well, here are mine anyway: • Smaller financial institutions with up to 50 staff members tend to: • Have a higher % of false positives particularly when they process smaller number of transactions per day (up to 100 or up to 500 per day) • Higher inclination of using integrated/shared processes • Conduct manual OFAC checks of trade-related documents whether in international or domestic • Have a centralized point of contact and internal escalation process • Medium-sized financial institutions of 51-200 staff members tend to: • Have higher % of false positives when they process smaller volumes compared to higher volumes • Have integrated/shared processes • Does not have a centralized point of contact or internal escalation when there are less processed transactions • Perform manual OFAC checks of trade-related docs • Larger financial institution of more than 500 staff members tend to: • Higher % of false positives with higher transactions • Have integrated/shared processes as they process more transactions • Have centralized point of contact • Have internal escalation process • Perform manual OFAC for larger transactions per day RESTRICTED