Is there or is there not a requirment to search the payees on checks if cashed by a non-customer against the 314(a) list for a period of 6 months? I have had one auditor tell me that it is required and another one tell me that it is not. I know it is an OFAC requirement, but this is the first I have heard of 314(a). I am just confused and want to do it right. The Exam Manual Says this:
Upon receiving an information request,a financial institution must conduct a one-time search of its records to identify accounts or transactions of a named suspect. Unless otherwise instructed by an information request, financial institutions must search their records for current accounts, accounts maintained during the preceding 12 months, and transactions conducted outside of an account by or on behalf of a named suspect during the preceding six months.

Discussion of specific 314(a) requirements should be limited to the private forums.

Your question is answered explicitly on the FAQ's available to your bank when you dock with the Mothership to download your lists. Its a dissappointment that neither auditor, particularly the one who answered your question correctly, thought to refer you to that resource

Thank you! I do not perform the searches myself, but I will have the person that does, check for me. Thanks again!