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#361912 - 05/20/05 02:55 PM Foreign Currency Exchange--OFAC and FinCEN?
Anonymous
Unregistered

My bank is housed in a resort community and during the summer season we often do foreign currency exchanges and sales for non-customers. Do we need to do an OFAC and FinCEN (section 314a) name check for these customers? Where can I verify this information? Thank you!

P.S. Sorry--I posted this under the wrong heading at first.

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#361913 - 05/20/05 07:13 PM Re: Foreign Currency Exchange--OFAC and FinCEN?
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,844
Pulling people out of the ditc...
exchanges, I don't think so. Sales, most definitely.
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#361914 - 05/20/05 07:30 PM Re: Foreign Currency Exchange--OFAC and FinCEN?
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Checking OFAC is always "risk based," you will not find anything that says you don't have to check any certain type of transaction. Queries under 314(a) simply don't include currency exchanges or sales in their search parameters.

You may have difficulty finding anything in writing on your fact situation because it may be difficult for regulators to believe that, in the current environment, a bank would be providing these types of services to non customers.

Unless the amount you would exchange for a non customer doesn't exceed taxi fare, I would encourage you to reconsider the practice.

If you have internal controls that you feel legitimize the practice, I would appreciate hearing about them. That's not so I can challenge you, just so I can learn.
Last edited by Ken_Pegasus; 05/20/05 07:39 PM.
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