Question: I recently attended a seminar that stated you should rent a safe deposit box with no need to check OFAC. Upon the customer returning, you would then check OFAC and only if they tried to remove items from the box would an officer confiscate what was being removed. Is this the correct way to handle safe deposit boxes or should you check before renting and make a decision there? Is it because you do not have any control until the items are in your posssession and therefore can't do anything until they are being removed from the box?
Answer: Technically, you should not provide a service for an entity or individual listed on the OFAC list, so you should be checking the list before you rent the box. Once you have rented a box and contents come within your possession, if you determine the renter is on OFAC's SDN list, you must freeze the box, deny access to the renter, and file a report of blocked property with OFAC.
The original version appeared in the March 2003 edition of the Oklahoma Bankers Association Compliance Informer.
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