Question: If we actually have a hit on the OFAC list, do we need to file a Suspicious Activity Report?
Answer: If only the name of a customer matched the information on the OFAC List - and there is no other independent evidence of suspicious activity -- a financial institution could file a voluntary SAR and state in the narrative section that the filing was made due to the name appearing on the OFAC list, according to OFAC. Such a filing is not required, however. If you are aware of activity which meets the definition of suspicious activity under the SAR instructions, however, you should file a SAR.
The original version appeared in the January/February 2003 edition of the Oklahoma Bankers Association Compliance Informer.
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