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Which test should be included in a bank's Office of Foreign Assets Control sanctions screening audit program?
In which case should an investigator avoid escalating a suspicious event to the chief compliance officer and pursue other channels?
A compliance officer of a financial institution is reviewing a payment for sanctions compliance between two parties in Europe and Asia. The payment is in Euros and involves the provision of services to a company located in a jurisdiction subject to Office of Foreign Assets Control secondary sanctions. Which factor is most important in determining the compliance officer's response?