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#409211 - 08/16/05 09:48 PM
exam manual and OFAC
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Anonymous
Unregistered
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on page 208 item 6 second bullet it states:
""Sample appropriate transactions that may not be related to an account (eg, funds transers, monetary instrument sales and check cashing transactions), and evaluate the filtering criteria used to search the OFAC database, the timing of the search, and documentation maintained evidencing the searches"""
first we wonder what they mean by "not related to an account". does that mean non-customers with a customers payroll check to caah. the transaction is related to an accountholder but the person standing there is not a customer and is only related by payroll??
second how would a teller document the search and results. put that on the back of the check, make all kinds of copies and put them into a file, what?
is anyone running OFAC for all the checks they cash?
is anyone running OFAC for all the travelers check, money orders and cashiers checks that they sell??
tellers with lines backed up have a priority to take care of those customers and even thought this is really not new the emphasis of tracking the search and results will add more work to an already busy place.
anyone willing to share their thoughts. please
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#409212 - 08/17/05 02:14 AM
Re: exam manual and OFAC
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Diamond Poster
Joined: Nov 2000
Posts: 1,820
Southern California
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There is no requirement to check the payee on a check presented at the teller window. Every bank should perform an OFAC risk assessment. Based on the risk assessment you can decide if verifying payee names makes sense for your bank. You may decide that the chances of a hit are remote and decide to keep that teller line moving.
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Dolly Nugent
CRCM
Opinions expressed are my own.
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#409215 - 08/18/05 03:42 PM
Re: exam manual and OFAC
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Anonymous
Unregistered
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Another reason NOT to do business with non-customers. 
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#409216 - 08/18/05 03:54 PM
Re: exam manual and OFAC
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Anonymous
Unregistered
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Hey, I thought they were singing the "risk managment" song these days?
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#409217 - 08/18/05 04:53 PM
Re: exam manual and OFAC
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Gold Star
Joined: Oct 2004
Posts: 327
Upstate N.Y.
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So what they are saying is that there is a higher probability that the payee on a bank check will be on the OFAC list if the check is purchased by a non-customer??? So if we sell bank checks only our own customers, the risk of having an OFAC hit on the payee is less. Still does not sound consistent with the message I've been hearing...let's see what the Regulators in NYC say on Monday.
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#409218 - 08/18/05 05:10 PM
Re: exam manual and OFAC
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10K Club
Joined: Jun 2005
Posts: 10,395
Jersey Shore
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Quote:
So what they are saying is that there is a higher probability that the payee on a bank check will be on the OFAC list if the check is purchased by a non-customer???
No, silly, that's not what they're saying.. What they're saying/implying/assuming/whatever is that your customer is going to be scanned against OFAC on account opening, information changes, list updates, and other kinds of transactions. With a non-customer, this transaction is your one and only chance to scan them in connection with a transaction.
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#409219 - 08/18/05 05:22 PM
Re: exam manual and OFAC
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Diamond Poster
Joined: Mar 2002
Posts: 2,355
The O.C., California
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Quote:
Quote:
So what they are saying is that there is a higher probability that the payee on a bank check will be on the OFAC list if the check is purchased by a non-customer???
No, silly, that's not what they're saying.. What they're saying/implying/assuming/whatever is that your customer is going to be scanned against OFAC on account opening, information changes, list updates, and other kinds of transactions. With a non-customer, this transaction is your one and only chance to scan them in connection with a transaction.
AML, you may have misunderstood. They are talking about the PAYEE , not the purchaser of the official check.
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I can explain it to you. I can't understand it for you.
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