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#1908641 - 03/26/14 01:18 PM Incoming ACH on OFAC List
Diana Timberlake Offline
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Diana Timberlake
Joined: Apr 2002
Posts: 118
If we receive an incoming ACH with the Originator's name being a match to a name on the OFAC list, how should it be handled? On an incoming ACH we have no information other than a name so we have no way to determine if in fact it is a match.

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#1908647 - 03/26/14 01:31 PM Re: Incoming ACH on OFAC List Diana Timberlake
Xian Ngyuen Offline
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Posts: 221
First things first, segregate the funds.
Your ACH batch can only be settled in part.
Is the name listed on a program that requires blocking, or one that permits rejection?
Second, ask the sending financial institution for whatever information you need to disqualify the match.
If no information is forthcoming, ask advice from OFAC.
Be prepared to treat it as a true match, with the required reporting to OFAC, and naming the sending institution.
Last edited by EdSpenser; 03/26/14 01:31 PM.
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#1908712 - 03/26/14 03:17 PM Re: Incoming ACH on OFAC List Diana Timberlake
ACBbank Offline
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ACBbank
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New York City
Usually originating FI's handle OFAC compliance in this example. As Ed mentioned, I would try to call the originating FI for more info. If it's an actual match, the steps you take would depend on the actual sanction program that the party falls under.
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#1908721 - 03/26/14 03:34 PM Re: Incoming ACH on OFAC List Diana Timberlake
edAudit Offline
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edAudit
Joined: Jul 2008
Posts: 4,796
You are here
Also you may wish to determine that the list that is scanned is for SDN (OFAC)only and not some other list such as PEP.
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