Is there any way to keep track if a teller does a OFAC check on cashing checks for non-cusotmer? I have been told that you must do an OFAC check on non-customer cashing checks. How can I prove that an OFAC check has been made other than the teller noting it on the cash ticket. Most of them forget to note it.

That is simply incorrect. When and where your bank does OFAC checks is a function of its OFAC risk assessment.

Texas,
Based on our risk assessment, we do OFAC non-customers. Currently, we do a screen print of the OFAC check done through our Core Processor and our BSA officer keeps a file of the checks.

As you can imagine this is a bit of a paper waster, so we are toying with the idea of using stamps to document the OFAC verification on the item. Something that would document the date and who completed the check. For an exam or audit, we could then go to the audit trail within our Core System to show that the check was completed.

We are still trying to determine if the new option would work, but we definitely do document and OFAC checks that we do.

-nell

Doesn't your core system give you reports that tell you when OFAC was performed?

Ken is correct. Most, if not all, banks regard OFAC as a function of Risk. What may be acceptable for your FI, may not be acceptable at mine.

Your OFAC risk assessment should dictate how you approach each situation.