We have a situation where the INS issued an Authorization for Employment card to a Cuban citizen. He came in to our Bank to open an account, presented the INS card and completed a W8 stating his permanent residence was in Cuba. We declined to open the account because Cuba is a sanctioned country. Plus the INS card is not a form of acceptable primary ID.

How come our own government agencies aren't required to screen applicants for ITINs, Right To Work SSNs, Authorizations for Employment, etc. against the OFAC list the way financial institutions are? This is ridiculous.

Pretty convenient, isn't it? I agree. It is also ridiculous that the Treasury could issue a tax refund check to a SDN and a bank could get fined for cashing it.