Our wire department logs in all OFAC hits though we have never had a match. We are getting matches on part of the word CORPORATION because the WORD is so long it splits the @ "CO" "RPORATION'. Always from the same originator - maybe 15 times per month. Always hitting on the same suspected match name that does have 'corporatopn' in the name. Can I have a disclaimer with my log that says something like this is not a match and will not be entered in the log?

I may not be the best person to answer this, because I use an automated system that logs the transaction scan even if I've 'whitelisted' a specific name or character string that hits repeatedly without being a true hit.

So, my advice on how to run a manual log should be taken with a grain of salt.

Let me just suggest that you have a couple of different issues to care for, so it's not really a simple yes-or-no answer.

One issue is demonstrating that the wires have been OFAC scanned, you don't want to do anything in your log practice that impairs your ability to show that a given wire has been scanned.

Another issue is that a whitelist is not a list of general things, it's a list of very specific entity names and/or addresses that you've verified are not true list matches. Also, that list itself needs to be reviewed whenever the OFAC list itself changes so you can continue to verify that the entity is not a true match.

I hope this helps.

This isn't really where I need to ask this, I guess but here goes anyway. Do we do the Red Flag on Minors?