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#1696085 - 05/04/12 07:29 PM PEP List
hollysiep Offline
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Joined: Feb 2006
Posts: 10
I did an OFAC scan on an International ACH Transaction and the person the money was sent to was flagged as a hit by our OFAC software. Upon further investigation the hit was due to the person being on a PEP list. Do I need to do anything with this as far as OFAC is concerned?

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#1696099 - 05/04/12 07:39 PM Re: PEP List hollysiep
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
OFAC has nothing to do with PEP's. Assuming that your customer, PEP or not, isn't on the SDN List, OFAC could care less how you handle the situation. That aside, your overall BSA Compliance program should have a procedure in place to determine if this individual is actually a PEP and you should respond accordingly.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#1696114 - 05/04/12 07:50 PM Re: PEP List hollysiep
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
What is a PEP list? I know what a PEP is, but is there a list?
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My opinion is mine only- not my employer's!


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#1696123 - 05/04/12 07:58 PM Re: PEP List hollysiep
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
There isn't an official government sponsored PEP list like the SDN List Jenny. However, many software providers have their own verions of "PEP" Lists.
Last edited by ACBbank; 05/04/12 07:58 PM. Reason: clarification
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#1696157 - 05/04/12 08:46 PM Re: PEP List hollysiep
AquaMarine Offline
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Joined: Jun 2011
Posts: 156
New York, NY
Adding to ACB's comment, you should look into third party softwares such as World-Check or World Compliance.

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