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#1169020 - 04/23/09 05:35 PM OFAC for Wire Transfers
JDMPAM Offline
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Joined: Mar 2009
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Should a bank run an OFAC check for both incoming and outgoing wires? Also, should the receiving/sending bank be checked (e.g. if one of your customers sends a wire to another individual whose account is with Chase do you OFAC the two individuals only or do you need to check Chase as well)?

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#1169076 - 04/23/09 06:03 PM Re: OFAC for Wire Transfers JDMPAM
Hrothgar Geiger Offline
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Hrothgar Geiger
Joined: Jun 2005
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In my opinion, yes, incoming and outgoing, all parties, all banks, all obi and bbi notes.

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#1169079 - 04/23/09 06:04 PM Re: OFAC for Wire Transfers JDMPAM
AuditorK Offline
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PA
The decision of who to run against the OFAC list is a matter of your bank's risk assessment. I believe that most, if not all, banks run every name in a wire record (individual, entity, bank) against the OFAC list to be on the safe side.

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