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#1943384 - 07/21/14 03:45 PM OFAC Scan on Board members of business customers?
AUTigers65 Offline
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Joined: May 2006
Posts: 57
Is it the norm to scan Board members of businesses that are in a bank's customer base against the OFAC list? I know that OFAC requirements generally include all account beneficiaries, signers, etc, etc. But are our customers' Board members actually our customer too, at least for OFAC considerations?

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#1943393 - 07/21/14 03:50 PM Re: OFAC Scan on Board members of business customers? AUTigers65
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The norm? No.

Some banks scan the names of an entity's beneficial owners. From memory, if an SDN owns 50% or more of an entity, the entity is considered to be an SDN as well.
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#1943431 - 07/21/14 04:24 PM Re: OFAC Scan on Board members of business customers? AUTigers65
Xian Ngyuen Offline
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Joined: Aug 2013
Posts: 221
It's a topic that should be covered in your OFAC policy.

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