Hi - Need help quick. We are a small community bank that has never had a possible OFAC hit before. We received a wire today and the originator's name came up as a suspect. It is not the same address - THE OFAC lists the address in Colombia. It just so happens to say in the FBO portion of the wire info (Land Payment in Colombia). I am currently on hold with OFAC Hotline to see what I can do since I do not have the DOB or Passport information for this individual. What should I do at this point? We have not processed the wire yet - I am trying to see how to handle it properly. Any advice would be greatly appreciated. Guess there's a first time for everything!

Call the originating bank and ask for the additional information. They might hesitate with privacy laws, but explain that it is in regards to the wire and a possible OFAC hit. Hopefully they will be willing to assist you, if not the OFAC hotline service personnel will want to know this and can contact them on your behalf, but they prefer you to get the information first.

This happened to me. If you call OFAC, there are going to want you to contact the other bank and find out DOB. If it does not match, just note the DOB on the OFAC report and you're done.

I have placed two calls to the originating bank and other than telling me that the DOB did not match, they will not provide me any additional information on the customer. I was on hold with the OFAC hotline for awhile and finally left a message but have not heard back from them. Any suggestions on what I should do with this wire in the meantime? I am just a little frustrated.

Did they give you the DOB? Ask them to give it to you. Document who you spoke to and then call OFAC again. Do not wait for them to call you back. In the meantime I would not credit the wire.

For what its worth, the OFAC hotline has always told us that even a different address means that it is not the same person.

So what happened?

OFAC called me back (from my first call when I left a message). I was on hold for the second time (1 hr 15 minutes into call) when they told me OFAC was on hold for me! I explained the situation and she said that as long as the other FI said that the DOB did not match, they did not consider it a hit and I could process the transaction. She also thought that the other FI should have been more helpful. Hopefully I don't have to worry about that again for awhile. Thanks for the thoughts and suggestions.