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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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.