When the list is updated, when is it required for bank's software to be updated to include that name on the list?

We do ours immediately unless it's at the end of the day. I'm in a wire room and downloading the list late in the day interferes with production (we do about 25,000 wires per day). But we usually receive updates prior to noon in which case we download right away.

Yes, but how quicly do you get the update. The day OFAC announces it?

We do it the day that OFAC sends us the new list, unless like I said before, it comes late in the day. Then we do it prior to opening the following day.

There are no requirements to have OFAC software. There is no OFAC requirement to check customers. There is no OFAC requirement to do anything except make sure you don't pay funds to someone on the blocked list.