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#392352 - 07/27/05 07:14 PM OFAC, 314(a) and MIs
Anonymous
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Our bank uses our customer database to search for the OFAC and 314(a) lists. Therefore, I changed policy to prohibit the sale of any monetary instrument to non-customers. Branches are now balking because they have many non-customers coming in with large checks drawn on good customers (mostly lawyers) of the bank and the non-customers are wishing to cash a portion of the check and get a cashier's check for the remaining. Would the non-customer be considered the purchaser (therefore requiring us to check their names against the lists)? Or can we consider this an exchange and not have to check their names?

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#392353 - 07/28/05 12:26 PM Re: OFAC, 314(a) and MIs
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
You could - if your bank is willing to take the risk.
Only you can decide that.
If one of those persons should be on OFAC you could be liable for a fine for issuing the check - the non-customer would be the purchaser.

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