I am looking for ideas, since we are brainstorming here. A little bit of background, retail bank with around 700 wires a day of which 50% are international. We have had the OFAC screening done by our payments area for operational reasons while the overall OFAC compliance is done by the compliance department. We have noticed (maybe because of staff changes) that a couple of hits had been accepted and processe by the payments group even when our interdiction software detected the hits. We have increased the training, but I am worried.

Will you move the screening function to compliance? Maybe get a compliance person in payments? What is the structure in your banks?
Thank you

LIC, we use Bridger software, and if the hit comes to a 80% match, the branch people call either compliance or BSA, we then run the name and make a determination. We have never had an actual hit, except on a PEP, which isn't OFAC anyway.

Similar to DQ, if a match scores more than xx, it escalates to compliance for review and disposition.

That would be my recommendation as well, a positive match must be escalated to a specified person or dept for resolution.

We do a large amount of international wires also and often get hits on names, but like Devil Queen said, most are due to PEP. However the BSA Dept has trained the wire area to review what it says on the match. If it is due to a similar name and they are able to determine it is an obvious false positive they are allowed to make their comments and continue on. If it is a 100% match, they contact BSA and get approval.