#346395 - 04/13/0506:18 PMMaintaining OFAC SDN list
Anonymous
Unregistered
We do not currently maintain a hard copy of the SDN (specially designated nationals) list. Our data processor maintains a list for us and checks our customer database at least monthly or upon word from OFAC that a change has been made to the list. Is this procedure acceptable or are we required to keep a hard copy of the list? Thanks.
No hard copy is necessary and is not encouraged, because the list changes so often. If your data processor does a scrub on a regular basis and when there is a change, then you are doing all that is required. I assume your new accounts are checked at time of opening, and that wires are checked on receipt and before sending?
One thing your examiner will ask -- How do you check against the SDN lists if the automated source is not available? One way to address that issue is to keep one printed copy available, or to download a copy of the ASCII file of SDNs each time it changes, so you can do a quick search with a PC when data links are down.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
Several months ago, I set up a desktop shortcut to the OFAC SDN list website on all of our CSR's and Loan Assistant's computers. They simply click on the icon and the updated list appears. They click on the binoculars on the menu bar and perform a quick search. We think it works great. The web site is www.treas.gov/offices/enforcement/ofac/sdn/t11sdn.pdf. If this link does not get you there, type this web address in manually.
Oh, and our wire department has the ofac sdn list link, also. They check originators, beneficiaries, banks, etc. Just takes a minute or less. The examiners were impressed.
Quote: Several months ago, I set up a desktop shortcut to the OFAC SDN list website on all of our CSR's and Loan Assistant's computers. They simply click on the icon and the updated list appears. They click on the binoculars on the menu bar and perform a quick search. We think it works great. The web site is www.treas.gov/offices/enforcement/ofac/sdn/t11sdn.pdf. If this link does not get you there, type this web address in manually.
Not to beat a dead horse (well, maybe I'll kick it a bit), The www.treas.gov web site was down most of yesterday afternoon (3/13/05). Keeping a copy of the pdf file on an intranet server as a backup might be desirable.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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