On January 12, 2006, the Office of Foreign Assets Control (OFAC) issued an interim final rule (Interim Rule) to describe economic sanctions enforcement procedures for banking institutions. The Interim Rule, which applies to "banking institutions," which are depository institutions supervised or regulated by a federal banking regulator, provides a general explanation of the procedures that OFAC will follow with respect to economic sanctions violations. The Interim Rule addresses issues such as the circumstances under which OFAC will provide a depository institution an opportunity to respond to an alleged violation and the factors that OFAC will consider in deciding its course of action. One such factor is the "quality and effectiveness of the banking institution’s overall OFAC compliance program." The Interim Rule also includes two annexes. Annex A is a chart that lists different factors that indicate a low-, moderate- or high-risk for purposes of developing or assessing an OFAC
