The OCC indicated that we should also be completing an OFAC search for new/potential hires. I can't find anything specifically addressing this.

Does anyone else complete searches on new/potential employees?

If they open an account, OFAC is checked - same as anyone else that opens an account.

There is nothing that I know of that requires an OFAC review relating to potential new employees. Did the OCC put that thought in writing or did an examiner simply mention it to you? If it's in writing, you had better come up with a plan to do the search, if not it may be one of those urban legends with nothing that you have to do.

If it's in writing, perhaps they now want us to check OFAC when anyone even thinks about doing business with a bank or working for a bank.

We have OFAC searches included in our credit reports, and we pull credit reports on all new hires. So we get the OFAC search without any extra effort, and the extra cost is literally pocket change.

Same here - they also get checked when they open a new account and during our monthly database comparison. Probably overkill but oh well....

Opinions are mine and mine alone.

When you think about what OFAC actually says, you should not only be checking new hires against OFAC but you should be checking vendors, etc. as well. Those on the list may not transact business with US entities or individuals. If you can't give them a bank account, you certainly can't give them a job. The regulators have been pointing this out to banks for the past year or so. When I first heard it I couldn't believe it hadn't occurred to me! It's one of those things that is right in front of you but we have been so focused on the account aspect, we never got beyond that!

O.K., and while you are at it, you should probably run your name through OFAC, just in case.

I actually did run my name for the heck of it - Thank goodness I wasn't there!

We do it as part of our routine OFAC search. Every employee has to be set up on our system in order to be an employee, whether they open an account or not.