Checking "PUPID" Wires Against the OFAC List
Answer by Ken Golliher, BOL Guru Guru Bios
Question: We currently check our wires against the OFAC SDN list. Is there any specific procedure for wires that come in Pay Upon Proper ID (PUPID)? Should we handle these wires in the same manner as regular wires?
Answer: Assuming you check every field on other wires, handle these the same way. Acceptance of PUPID wires will have a significant effect on your bank's BSA/AML & OFAC risk assessment.
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