Just when I thought I knew BSA my boss hit me with a stumper. According to him OFAC checks are checked against up to 22 differing lists. Which lists does a financial institution have to check to be compliant?

Thanks in advance everyone....

Ohhh...your boss is a WISE GUY, eh?! Nyuk, nyuk, nyuk!

Seriously, I think that the only time you have to worry about which list an SDN is on is when and if you get a true match. Then, the list that they are on will determine whether you block the transaction or freeze it. Since most of us would likely find out about there OFAC status after the fact (absent real time OFAC checking by frontline employees), the point may be moot.

The OFAC list is like a major river that results from a watershed. There are a number of federal laws that generate lists of individuals, companies and countries that are subject to sanctions. Those are all streams flowing into the OFAC river. As Anon 357811 indicated, which stream they came from only becomes relevant when you get a hit. Then, you trace it back to its source and figure out what to do.

As for which of those contributing lists you must check, the answer is: None. Checking the OFAC list is risk based; you do it because the cost of checking is miniscule compared to the potential penalties for dealing with a listed party.

As Anon 357824 said, there are bunches of other lists that are of varying importance that have nothing to do with OFAC. Reviewing them is also a risk based decision.

This has been very insightful. Thank you. Ken, we do complete OFAC checks on all customers as our Bank has determined that we should based upon its Risk Assessment. But I do realize that this sort of thing is Risk based (thanks ).

However, the way our check works is we get to have all 22 of these lists checked individually and the system releases a report to us. I was curious which portion of the list is considered most important. I will be able to provide the individual lists it checks next week.

Thanks for the insight everyone.

My best guess is that you have a vendor that checks the OFAC list and 21 others. Some vendors include the "10 Most Wanted," Inspector Renault's "usual suspects" from Casablanca, and the list of jurors from the Scopes monkey trial and then market their inclusion as some sort of value-added proposition.

In candor, it isn't - their presence causes you to waste a lot of effort when you get "hits" and then spend time trying to figure out exactly what it is you are supposed to do. Ask your vendor for a list of the lists they use.