As a companion to the Tracker Database Infrastructure Rewrite project, we will be pulling all data related to OFAC and FinCEN 314(a) scans into their own, separate database. Since OFAC scans currently comprise a very large portion of the Tracker database, this also not only make it easier to research details about OFAC scans, but will also create a leaner, more nimble database for normal Tracker functions.

New dashboards will also be created, with search and filter capabilities, making it easier than ever to provide compliance documentation to auditors and examiners. An automated purge process with configurable timeframes will allow data to be retained according to regulatory requirements and CU preference.

The database will store all scan information for both members and non-members in the same place, with records marked as to whether the person was a member or non-member at the time the scan was run.

Since OFAC scan overrides on members are currently stored as Tracker Notes, we will be creating a new mechanism to store comments when an override is performed (whether a member or a non-member), to be stored as part of the OFAC scan history going forward.

Note: Because of the volume of records for these scans, we will likely be changing where the new tables will be stored and adjusting the frequency of regular backups. You’ll hear more about that as final details are determined. OFAC scan history will no longer be archived to CU data warehouses.

What about Existing OFAC Scan Trackers?

When the new structure is deployed (likely in a phased rollout over a period of a few weeks), we’ll be running a conversion routine that will:

• Copy all existing Tracker records under the AT Audit Tracker type that have the following memo types:
  • OO – OFAC Scan Passed
  • OF – OFAC Scan Failed
  • OO – OFAN Scan Override
• Copy all non-member OFAC scans from the existing OFACNOTE table
• Copy in all FinCEN 413(a) scan records from the existing OFACNOTE table
• Mark all records in the new table as either member or non-member

All OFAC-related records will then be removed from the old Tracker and OFACNOTE tables and no longer visible through existing reports or inquiry tools. You’ll need to use the new dashboards to view details for research or auditor inquiries.

The Projects

Note: In order to manage the time required to convert Trackers to their new structure (described in the separate recipe), these projects will be implemented before the rollout of the Tracker Rewrite project.

Your chef for this recipe: Dawn Moore