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You work in the compliance department of an American bank whose management is concerned about the number of times it has been fined in recent

You work in the compliance department of an American bank whose management is concerned about the number of times it has been fined in recent years because of unwitting involvement in transactions that violate current economic sanctions administered by OFAC. You have been asked to write an in-house procedure manual that explains how best to determine whether a proposed transaction may violate a current government sanction and, if so, what steps bank personnel should take to avoid violating the sanction. Your procedure manual should be between four and six double-spaced pages and should focus on general principles that could be adapted by individual bank departments for their specific transactions

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