Implementing the OFAC/Patriot Act Initiative for Auto Dealerships

The USA Patriot Act requires that organizations verify customer profiles; business names, addresses, and other identifying data; to check that entities opening commercial accounts are indeed legitimate businesses; and that customer names do not appear on lists of known or suspected terrorists (as required by the Office of Foreign Asset Control, or "OFAC"). Businesses that fail to verify such data may face financial risk, regulatory penalties, and damage to their reputations. The OFAC Program is intended to train employees on the topic and ensure that the appropriate policies and procedures take place each time a sale is made at your business.

OFAC is a special unit of the U.S. Treasury Department responsible for enforcing trade and economic sanctions against countries, businesses and people who have been designated as hostile to the United States. Among other things, the regulations that OFAC enforces play a role in combating money laundering and terrorism.

Implementation Steps in this Guide

1. Edit and Distribute the OFAC Compliance Policy

2. Review and Edit the OFAC List Match Procedures Guideline

3. Distribute the “OFAC Anti-Terrorism” Training

4. Schedule the Office of Foreign Assets Control (OFAC) Compliance Certification Form for Distribution

5. Allow Employees to Start the Suspected Misconduct Report Form

Edit and Distribute the OFAC Compliance Policy

Edit the policy

1. Click on the Library tab
2. Search for "OFAC Compliance Policy" and click on it
3. Click on the Edit button to view the list of versions
4. Click Create Draft to the right of the latest published version
5. Click Edit next to the Draft version that you just created
6. Make desired changes to the policy
7. Click Publish when you have finished editing the policy

Schedule the activity for distribution

1. Click on the Workspaces tab
2. Click on the Consumer Finance workspace
3. Click on the OFAC initiative
4. Click on the OFAC Compliance Policy
5. Click on Groups and assign to the appropriate group(s), such as managers, controller, sales, finance and insurance, cashiers, and anyone who participates in a sales transaction.
6. Click on Schedule and set an annual schedule based on the Hire Date. We recommend that you set the Immediate Distribution option to Yes. 
7. Click Save

Review and Edit the OFAC List Match Procedures Guideline

1. Click on the Library tab
2. Search for "OFAC List Match Procedures Guideline" and click on it
3. Click on the Edit button to view the list of versions
4. Click Create Draft to the right of the latest published version
5. Click Edit next to the Draft version that you just created
6. Make desired changes to the guideline
7. Click Publish to finish editing the guideline
8. Click Permissions and assign to the appropriate group(s), such as managers, controller, sales, finance and insurance, cashiers, and anyone who participates in a sales transaction.

Distribute the “OFAC Anti-Terrorism” Training

1. Click on the Workspaces tab
2. Click on the Consumer Finance workspace
3. Click on the OFAC initiative
4. Click on GLBA Privacy and Safeguards Training
5. Click on Groups and assign to the appropriate groups, such as managers, controller, sales, finance and insurance, cashiers, and anyone who participates in a sales transaction.
6. Click on Schedule and set an annual schedule based on the Hire Date
7. Click Save

Schedule the Office of Foreign Assets Control (OFAC) Compliance Certification Form for Distribution

The company Compliance Officer is required to complete this certification once per quarter so the company can maintain current and accurate records demonstrating compliance with the rules relating to the Department of Treasury's Office of Foreign Assets Control Specially Designated Nationals List.

Review the Process Workflow

Set the form routing

1. Click on the Admin tab
2. Click on Workflow/Forms subtab
3. Click on Processes
4. Search for and click on Office of Foreign Assets Control (OFAC) Compliance Certification Form
5. Edit the routing rules for each stage by following these suggestions:
   
   

   Stage	Suggested Routing Rule	Description
   Compliance Officer Section	Subject or Queue	Route to the "Subject" (i.e. the person to whom the system sent this form), or to a queue that contains your Compliance Officer, or equivalent.
   CFO Section	Queue	Route to a queue that contains your Chief Financial , or equivalent.

Schedule the Activity for distribution

1. Click on the Workspaces tab
2. Click on the Consumer Finance workspace
3. Click on the OFAC initiative
4. Click on the Office of Foreign Assets Control (OFAC) Compliance Certification Form
5. Click on Groups and assign to the appropriate group(s), such as your Compliance Officer
6. Click on Schedule and set the appropriate schedule. We suggest a quarterly schedule.  
7. Click Save

Allow Employees to Start the Suspected Misconduct Report Form

Use this form to report conduct you suspect violates the law or ethical business practices.  Examples of types of misconduct you may report on this form include document destruction, conflicts of interest, insider trading, money laundering, improper accounting methods, improper overtime practices or other similar inappropriate conduct.  No retaliation will result from good faith reports of suspected misconduct.

Review the Process Workflow

Set the form routing:

1. Click on the Admin tab
2. Click on Workflow/Forms subtab
3. Click on Processes
4. Search for and click on Suspected Misconduct Report Form
5. Edit the routing rules for each stage by following these suggestions:
   
   

   Stage	Suggested Routing Rule	Description
   Employee Section	Creator	Route to the "Creator" (i.e. the person who started the form)
   HR Section	Queue	Route to a queue that contains your senior Human Resources manager(s) and/or legal counsel, or equivalent.

Set the Activity to be startable by All Employees

1. Click on the Workspaces tab
2. Click on the Consumer Finance workspace
3. Click on the Suspected Misconduct initiative (Note: This form is kept in a separate Initiative because due to its general purpose)
4. Click on the Suspected Misconduct Report Form
5. Click Edit and set the Start Menu Folder to "Report an Incident" or something similar
6. Click Groups and assign "All Employees" (or another set of group as appropriate) within the "In Start Menu" for section. 
7. Click Save