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#1241395 - 08/28/09 05:11 PM OFAC on payroll and specific stored value cards
AnnRoy Offline
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AnnRoy
Joined: Jun 2002
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South
In addition to stored value cards, our bank offers payroll cards and family card. The family card is the VISA prepaid stored value card which reloadable where our customer is the card sponsor and funds the account from their checking account in amounts from $25 to $2,000, ona scheduled or as needed basis. This product is not on our core system.

I know the OFAC expectation is screened the employer -our customer for the payroll card and our customer as the card sponsor for the family card which gets scanned each time the OFAC list is updated b/c they're in the customer database. But what about the employees receiving the payroll card and the end-users on the family card - is anyone performing the OFAC scan?
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#1241493 - 08/28/09 06:05 PM Re: OFAC on payroll and specific stored value cards AnnRoy
BrendaC Offline
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Sweet Home AL
We consider payroll cardholders as "customers" for CIP, OFAC, Reg E and privacy disclosure purposes.

If the only way to fund the family card is through a checking account with your bank, they should already have been screened to OFAC.
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#1247653 - 09/09/09 10:50 PM Re: OFAC on payroll and specific stored value cards BrendaC
AnnRoy Offline
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AnnRoy
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Regarding the family card - This card is a reloadable VISA prepaid debit card. Spending is limited to the amount placed on the card by the purchaser (our customer). Each time the card is used to make a purchase, the amount is deducted automatically from the card’s balance. So our customer (the purchaser) is screened each time the OFAC list is updated. The maximum amount that can be loaded on the card is $2,000.
The cards can only be purchased online via our website and be funded either by ACH from a bank-held account or Card to Card transfer. So the end-user of the card doesn't have to be a customer of our bank (ex - my boys have this debit card with their name on it but I fund it via my DDA). So the end user (my boys) don't have an account with us, therefore no OFAC scan.

So we're getting "dinged" for this......
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#1247671 - 09/09/09 11:41 PM Re: OFAC on payroll and specific stored value cards AnnRoy
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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I suppose the thinking is this could be a way for you to funnel funds to me, and I am on the OFAC list.

Do you maintain a list of the people the cards are issued to that you could run against OFAC?

How did you rank this on your OFAC risk assessment?
Last edited by MS Kaybee; 09/09/09 11:42 PM.
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#1247839 - 09/10/09 02:30 PM Re: OFAC on payroll and specific stored value cards Kathleen O. Blanchard
BrendaC Offline
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BrendaC
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Sweet Home AL
Our card processor screens payroll and secondary (family) cardholders to OFAC.
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#1248041 - 09/10/09 04:03 PM Re: OFAC on payroll and specific stored value cards BrendaC
Kathleen O. Blanchard Offline

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That is what I would expect to see, Brenda. It fits well as an automated process that just happens.
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#1248076 - 09/10/09 04:25 PM Re: OFAC on payroll and specific stored value cards Kathleen O. Blanchard
AnnRoy Offline
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AnnRoy
Joined: Jun 2002
Posts: 771
South
I need to review the contract to see if the card processor is performing the OFAC scan.....but I seriously doubt it.

THANKS Kaybee & BrendaC for the responses!
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