Skip to content
BOL Conferences
Thread Options
#1167349 - 04/21/09 05:32 PM FinCEN vs OFAC
Golfer9 Offline
100 Club
Joined: Sep 2007
Posts: 199
Oklahoma
Is there a chart that outlines the differences between the FinCEN 314(a)lists and the OFAC SDN list?

Return to Top
BSA/AML/CIP/OFAC Forum
#1167363 - 04/21/09 05:38 PM Re: FinCEN vs OFAC Golfer9
Hrothgar Geiger Offline
10K Club
Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
That's sort of like asking for a chart the outlines the differences between chalk and cheese.

Return to Top
#1167456 - 04/21/09 06:55 PM Re: FinCEN vs OFAC Hrothgar Geiger
Deena Offline
Power Poster
Deena
Joined: Nov 2000
Posts: 2,701
PA
Golfer9, the 314(a) list is a one-time search requirement - i.e., you complete your search of your records and you're finished with that list. You don't search that list for subsequent customers or transactions. The OFAC list must be searched in connection with any or all customers, transactions, etc., as deemed necessary based on your institution's OFAC risk assessment.

Hope that helps.
_________________________
Opinions expressed are mine and not necessarily those of my employer.

Return to Top
#1168542 - 04/23/09 11:40 AM Re: FinCEN vs OFAC Golfer9
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
...a "hit" on a 314(a) list requires you to simply notify FinCEN and a "hit" on OFAC will require action that is based on the reason the customer is on the list, generally you will block the transaction.

Either type of hit should prompt some enhanced due diligence; i.e. a review of customer activity.

Return to Top

Moderator:  Andy_Z