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#1196095 - 06/04/09 06:28 PM OFAC screening for ACH Originators
DRN Offline
Junior Member
Joined: Jan 2003
Posts: 36
Virginia
I am trying to see what other banks are doing as far as IATs and OFAC screening. Do you (the ODFI) expect your originators to perform an OFAC screening before the files are sent to you or are you performing the OFAC screening?

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BSA/AML/CIP/OFAC Forum
#1196114 - 06/04/09 06:48 PM Re: OFAC screening for ACH Originators DRN
Hrothgar Geiger Offline
10K Club
Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
As far as IAT is concerned; gateways, ODFIs and RDFIs have a responsibility to ensure OFAC compliance. The originating customer (assuming they are a US entity) also has a responsibility to ensure their own OFAC compliance.

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#1196121 - 06/04/09 06:54 PM Re: OFAC screening for ACH Originators Hrothgar Geiger
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
However if one slips through and you don't catch it, your bank is just as guilty.
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#1196160 - 06/04/09 07:30 PM Re: OFAC screening for ACH Originators Skittles
Hrothgar Geiger Offline
10K Club
Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
That's a big 10-4, Duchess.

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