OFAC provides a matrix (see OFAC, Economic Sanctions Enforcement Guidelines 
Actions, pp 57607-57608) to help financial institutions evaluate their compliance programs.  OFAC lists the following under the “high-risk” category:
 
Overseas branches or multiple correspondent accounts with foreign banks.
The institution offers a wide array of electronic (e.g., e-banking) products and services (i.e., account transfers, e-bill payment, or accounts opened via the Internet).
Authority and accountability for compliance have not been clearly established. No OFAC compliance officer, or an unqualified one, has been appointed. The role of the OFAC officer is unclear.