Question: We currently do not get identification (we don't even get the purchaser's name) when we sell money orders unless the transaction involves $3,000.00 or more. This has never been an issue with the bank examiners but are we responsible if the money order is purchased by a person on the OFAC list or given by the purchaser to a person on the OFAC list ( the money orders are given without the payee and purchaser filled in).
Answer: Over the last few weeks there's been a great deal of discussion on this
subject on the Bankers' Threads message board on BankersOnline.com.
Most of the bankers are taking a position that I think is a reasonable
one: It all boils down to risk management. What is the likelihood that
someone on the OFAC list is going to be either a purchaser or named
recipient on an instrument of this type under the BSA recordkeeping
amount threshold?
Examine the likelihood of a "hit" in that scenario against the employee time and cost required to gather the additional information. Then make a business decision about whether you want to spend the time and effort to obtain the information, or skip it and risk the remote possibility that an OFAC-affected party could surface in that situation.
Those are the issues to be considered in determining what your approach should be.
The original version appeared in the January/February 2002 edition of the Oklahoma Bankers Association Compliance Informer.
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