27. What do I need to do to comply? Do I have to buy expensive software?

This is primarily a question for your regulator. What constitutes an adequate compliance program depends in large part on who your customers are and what kinds of business you do. Certain areas of bank operations, such as international wire transfers and trade finance, are at a higher risk than others. There are numerous interdiction software packages that are commercially available. They vary considerably in cost and capabilities. If your bank feels it needs to invest in software in its attempt to comply with OFAC regulations, OFAC recommends that you talk to your counterparts in other banks about the systems they have in place and contact vendors for an assessment of your needs. It should be noted that *.TXT and *.PDF versions of all of OFAC's sanctions lists can be manually scanned; OFAC also offers a free, online search engine at the following URL: Sanctions List Search (treas.gov)