I have a question about Cashiers Checks. When we have one of our customers purchase an cashiers check, who do we check against the OFAC list? Do we check the purchaser (who should already have been checked, due to being a our customer) and check the payee, who we would not have any information on them. I just can’t see how we can verify the payee. I would think that whoever is cashing the check for the payee would be the one to check. I would thing that we would only check for someone who is a non-customer (who we don't sell to in the first place.

There are a lot of good posts for this, (try to search) but it should be addressed in your risk matrix. Some core processer willl check this on all transactions. This is where I would start.( It may not be an issuue for you)

Whether or not you check payees on cashier's check purchases is a risk-based policy decision for your bank. Your bank needs to decide what its risks of facilitating a prohibited payment are, and those risk can vary based on your location, your clientele, etc.

You can't rely on "whoever is cashing the check" to check the OFAC lists. They check isn't supposed to get into an SDN's hands, and if it does, in a foreign country, do you really think that the Last National Bank of Iran is going to do the bidding of the U.S. government?

If a bank does check cashier's check payees and gets a possible match, the bank should enlist the aid of its customer, who is the one who wants the payment to be completed, to provide or obtain more information about the intended payee's address or other personal information that might be used to clear up the problem.