We are a de novo bank and our BSA officer mentioned that it was "recommended" by FDIC regulators that banks need to check their
correspondent banks on OFAC anytime they send or receive a wire from them. To me this seems pointless and quite excessive. We send/receive wires
through PCBB and I can't see us needing to check OFAC lists for their name daily. Is this really necessary?
What is required for cashier checks and money orders purchased at a bank in relation to OFAC?
The FFIEC Exam Manual refers to Politically Exposed Persons, as a "senior foreign political figure". We have Examiners here, who also have stated that they are only foreign political figures (and their families, close friends, & associates, etc...). But, we had a State of Arkansas House of Representative come up as a "hit" on the Enhanced Politically Exposed Persons (PEP) list when we ran them through the OFAC section of Chexsystems. So, I am just looking for some clarification or guidance on this.
If the OFAC list now contains a name that matches our customer’s name, should we immediately close the account?
When opening a new deposit account, not current customer, do we have to run the OFAC while the customer is sitting at our desk or can we run it after the account is opened? Do examiners have a preference on this?bri
What is an LEI? Do we have to use it to establish beneficial ownership certification?
Do we have to have a beneficial ownership certification on a nonprofit corporation?
What taxpayer identification number do we use on an LLC?
What is a series LLC?
What is a legal entity?