After the September 11, 2001, terrorist attack, the President issued an Executive Order requiring all financial institutions to immediately block any assets held in the names of individuals or organizations identified as being associated with a terrorist group and to immediately notify the Office of Foreign Assets Control. The number of “Specially Designated Nationals” on the list has increased significantly since the Executive Order was issued. These names, including aliases, have been distributed to you through our Regulatory Alerts issued in September, October, and November.
As part of NCUA’s responsibility to ensure federally insured credit unions comply with applicable laws and regulations, we have developed the attached checklist which an examiner may use in documenting the review of the credit union’s compliance with the OFAC regulations. I am providing this checklist to you for your information.