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.
