I work for an audit firm that conducts BSA/OFAC and other compliance audits. I was looking at the tab-delimited file that a bank exports from its core system to run through its OFAC software and saw that it only had the primary name of the business.

For example, when the existing accounts are periodically screened for OFAC, ABC Check Cashers with 5 signers only gets screened under the name ABC Check Cashers. The 5 signers' names are screened for OFAC compliance when the account is opened, but never again.

I think that this is a flaw in the system, but am curious what others are doing and whether you think I am being too "picky."

Thanks for your feedback!

I would like to bump this up, as we are curious about the same thing. We do not create a CIS record for all signers of business accounts. Therefore, they will not be screened regularly through OFAC. I'm not finding anything in the BSA examination manual or elsewhere that specifies if running the business name through OFAC is sufficient.

(Sorry I'm not logged in, but if I go log in now, I lose my place in the thread. This is Spladoodle.)

Just my opinion,

If you screened the signers on account opening, then they need to be screened on account update events, and on list update events.

OFAC compliance should be a risk-based decision in your institution.

OFAC prohibits you from conducting a transaction with anyone on the list. That includes account signers, IMO. However, your institution should make the decision as to whether the risks of conducting a prohibited transactions outweigh the costs associated with checking every signer.

Your client's system is not "perfect," but as Great Blue notes, it does not have to be perfect. The revised examination procedures emphasize the importance of the bank's OFAC risk assessment in its decison making. The flaw you note is common in community financial institutions. If they have done a risk assessment that indicates their risk is low, they may be able to defend the imperfection.

However, many of those currently entering the U.S illegally through Mexico are not Mexicans (I forget the acronym). The closer your client is to "the valley," the less likely a that they are "low" risk in terms of OFAC.

Just when I think we've gotten everything covered..... there you go! I give. I'm going to work at Walmart.