Skip to content
BOL Conferences
Thread Options
#348829 - 04/20/05 02:06 PM OFAC Blocked transaction
comprunx3 Offline
100 Club
Joined: Aug 2004
Posts: 149
SouthEast
Any advice on how to title an account in which blocked funds are being held. The funds are being placed in an interest bearing account - whose TIN is used?

Return to Top
BSA/AML/CIP/OFAC Forum
#348830 - 04/20/05 02:27 PM Re: OFAC Blocked transaction
Anonymous
Unregistered

When you have a true OFAC hit and the funds must be blocked (frozen), you place them in a separate interest-bearing account. [It must bear interest at a "commercially reasonable rate." That means a rate currently offered to other depositors on deposits or instruments of comparable size and maturity.] The title to the account is still held in the name of the designated individual, entity or organization, but that individual or entity cannot exercise the pwoers and privileges normally associated with ownership unless authorization is obtained from OFAC.

You would use the owner's identifying number as the TIN on the account.

Return to Top

Moderator:  Andy_Z