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.
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CAMS