11/01/2003
Ten years ago, the OFAC lists were largely geographic based. Now OFAC identifies targets using a list-based approach.
11/01/2003
When it comes to evaluating your OFAC compliance, examiners are doing much more than in the past. What happens if the examiner finds a problem with your OFAC program?
11/01/2003
Customer Identification was a leading topic at the 2003 ABA/ABA Anti-Money Laundering Conference, held in Washington, D.C. No surprise there.
11/01/2003
The agencies are in the process of publishing new examination procedures for the new components of anti-money laundering programs generated by the USA PATRIOT Act.
10/20/2003
Our tellers do an OFAC inquiry on the payee of a cashier's check before issuing it. What is our responsibility in the case of money orders? Many customers want the payee left blank.
10/13/2003
10/06/2003
We have software that can be used to run our customer base against not only the OFAC list, but also a more expansive list. The name list that the software contains in addition to the OFAC list, is an FBI list. My question is this, is the bank required, by any law/regulation/statute, to review any matches other than OFAC list matches? The matches we have appear to be simply common name matches, but obviously I don't want to be out of compliance.
10/06/2003
I am looking into the USA PATRIOT Act for our mortgage company and I think the credit bereaus we are using would be sufficient for CIP, I would like to know if the credit report alone be sufficent or would we need other documentation the reports include OFAC checks, address checks, name, and S.S. verification? Also if the credit reports are sufficient should we keep it in seperate file specifically for CIP?
09/29/2003
What is the proper way to handle a situation where you are opening up a new account for a new customer and their name shows up on your OFAC list? Do you continue your opening process and then report them to the proper authorities or do you stop immediately and turn the customer away?
09/22/2003
I have recently read in the material from an OFAC training session attended by one of our employees the following: <ol><li>When opening a safe deposit box rental, it is not necessary to check the OFAC list. I disagree with this. What is your opinion? <li>Regarding access to a previously rented safe deposit box, if there is a match to the OFAC list, access should be granted and a financial institution employee must be present. If any contents of the box are removed, the contents must be confiscated. This would probably be a risky situation for the employee. Wouldn't OFAC be contacted for instructions on how to handle it? Wouldn't it be best to have law enforcement present? What is your opinion? </ol>