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#1177063 - 05/06/09 05:59 PM New account - OFAC concern
AuditorK Offline
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Joined: Feb 2003
Posts: 962
PA
Is there a reason why a bank wouldn't be allowed to open a deposit account for a person from Iraq? The person appears to have a valid green card and SSN. I'm just thinking about OFAC sanctioned countries...

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#1177080 - 05/06/09 06:08 PM Re: New account - OFAC concern AuditorK
Hrothgar Geiger Offline
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Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
You would have to review the Iraq sanctions program, they are what I typically refer to as 'limited retriction', and the specific person.

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#1177100 - 05/06/09 06:19 PM Re: New account - OFAC concern Hrothgar Geiger
AuditorK Offline
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Joined: Feb 2003
Posts: 962
PA
From a preliminary review of the Iraq Sanctions, it looks like as long as the person doesn't appear on the OFAC SDN list, we should be okay. We also want to determine whether they are a PEP.
Last edited by AuditorK; 05/06/09 07:02 PM.
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#1179505 - 05/08/09 06:31 PM Re: New account - OFAC concern AuditorK
Dolly Nugent Offline
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Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
When in doubt call OFAC.
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Dolly Nugent
CRCM
Opinions expressed are my own.

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