We manually search all names of individuals, entities, and banks in a wire transfer record using OFAC software. My question is this - do we have a risk if we aren't checking country names? For example, Mr. Smith wants to wire money to ABC Bank with a beneficiary of XYZ Company who's address is in Cuba. The person handling our wires would run the following names through our OFAC software: Mr. Smith, XYZ Company, and ABC Bank. Since all transactions are blocked with Cuba, is it probable that this transaction would not be flagged and we'd allow it to be processed?

Yes, you are running a honking big risk by not scanning the address (including country) along with the name.

Specifically there are country-based programs in OFAC that you need to be able to address.

That's what I thought...just wanted to make sure I wasn't overlooking something. I wish management would agree to an OFAC solution that would automatically scan all fields in the wire record.

I agree 100%

Okay, I just went to our OFAC software and entered "Cuba" to see what would happen if we run a country name when doing our search of wire records. I got 1431 results. How does that help the person doing wire transfers to know that all transactions with Cuba are prohibited? I know not every Cuban citizen is on the OFAC list. Even if all 1431 of those potential hits were researched, there's a good chance the individual isn't listed and the wire would be sent.

Unless there is a license for the transaction, you may not facilitate a payment into Cuba. Period. Full Stop. Doesn't matter *who* in Cuba.

AK - You should be monitoring sanctions specific to countries, not just the OFAC lists. BOL's OFAC page has list of sanctions.

BrendaC - I gotcha. If I provide the person who handles the wires with a list of the countries under sanctions programs, she can check the countries in the wire records. If she finds a match, then further research into the program itself can be conducted. Thanks for all the comments!

That's what I used to do. Whenever a sanction program change occurred, I updated the wire room's reference tool.

We put out a desk-card with lists of countries on full restrictios, partial restrictions, and limited restrictions.

I'd love to see one of these. I'm not up to speed on who's under full, partial, and limited sanctions.

There's no shortcut, you've got to be familiar with the programs and their requirements. Then you can make a card for your own people.

A desk-top reference can be risky. Teach the wire dept. to use the OFAC website and have an approval or escalation process in place so that anything questionable gets a second look. SDN and sanctions change frequently.