I hope I am posting this in the correct category, well anyway here are my questions:

We had a 100% match for OFAC come up on a wire transfer.
The person who is receiving the funds is the one that came up. Our commercial customer is the one sending the funds out of their account with us.
We have temporarily stopped the transaction from happening until I hear back from the OFAC Compliance Hotline.
What I need to know are 2 things:

1) Would this be considered a blocked or rejected transaction. My thought would be rejected, because the funds are going out.
2) If we attempt to confirm the D.O.B. from our customer against the D.O.B that appears on the SDN is that good enough to say we can go ahead. I am somewhat leary on that one, because how do we know that we are being told the truth with regard to the D.O.B when we don't even have the recepient in front of us?

If anyone else has run into this type of situation with a wire transfer or can offer a helping hand I would appreciate it.
I left a message for OFAC but yet to hear from them.

Thanks

I had a similar one last year and we did not send the wire until OFAC gave us specific direction. It was considered rejected. We just told our customer there was some information we had to clarify before we could send the wire. OFAC advised us not to send it.

Redwriter:

Thanks for your info. As of yet, OFAC hasn't called me back.
Do you have better definitions of rejected vs. blocked.

I also think that this would be a rejected transaction, as well as reporting it on an annual submission report to FINCEN. Am I accurate with the rejected term vs. the blocked. To me when your blocking something, your blocking it from coming in?

Thanks

Actually, I believe it is the opposite. Blocking means blocking from going out, while rejecting is denying admittance. See the FAQ copied from www.treas.gov/ofac .

What do you mean by "blocking?"

Another word for it is "freezing." It is simply a way of controlling targeted property. Title to the blocked property remains with the target, but the exercise of powers and privileges normally associated with ownership is prohibited without authorization from OFAC. Blocking immediately imposes an across-the-board prohibition against transfers or dealings of any kind with regard to the property. [09-10-02]

Treasury has a website specifically for emailing OFAC questions regarding wire transfers in process. Maybe this would get you a quicker response. http://www.treas.gov/offices/eotffc/ofac/hotline.html

This is an excerpt from an article published by OFAC:

"Valid OFAC "hits" may need to be blocked or rejected, depending on the nature of the transaction and the applicable regulations. Deciding whether to block or reject can be difficult. Your bank's main compliance responsibility is to ensure that suspect items are interdicted. OFAC will help you determine whether an interdicted transaction ought to be processed, blocked, or rejected."

I've found this to be true that whether something should be blocked or rejected is confusing. Transactions to some countries must be blocked and others must be rejected. Sometimes it isn't so much what type of transaction it is, as where it is going.

I agree that the best way to handle this is to go through OFAC. (If they can give you some guidance as to definitions, be sure to post their response.)