If OFAC applies to all transactions does this mean new loan applicants also? Would CIP apply to a new loan applicant? When a person applies for a loan--what list do we check or should we be checking both the CIP and OFAC list and do we wait till closing to do this or upfront?

Continuing: When a person opens a new deposit account do we check both the CIP and OFAC list?

OFAC as you stated applies to all transaction, CIP applies to new customers establishing an ongoing relationship. For example if a new customer comes to your bank and applies for and is approved for a loan then you are required by regulation to perform CIP and by law not to conduct transactions with someone on the OFAC list. How do you do that? Well the only way I know of not to do business with someone on the OFAC list is to check them against the OFAC list.

Hope this clears things up.

There is no CIP list if you are referring to the Section 326 list that has not yet been provided to check at account opening.