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#115833 - 09/19/03 05:04 PM Incoming Wire / OFAC review
Miss Kitty Offline
Platinum Poster
Joined: Mar 2002
Posts: 721
California
Would someone be willing to assist in validating the requirement to have a procedure to validate that incoming wires should have an OFAC search to ensure that the funds received are not from any listed individuals or countries.

Thanks.

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Operations Compliance
#115834 - 09/19/03 05:22 PM Re: Incoming Wire / OFAC review
Retired DQ Offline
10K Club
Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
Cheryle, I can only think that "transaction" includes wires in and out. If you are sending or receiving a wire (or transaction) from a blocked country or an SDN, you are violating the rules.

This is from Treasury:

"Over the past several years,
OFAC has had to impose millions of dollars in civil penalties involving
U.S. banks. The majority of the fines resulted from banks’’ failure to
block illicit transfers when there was a reference to a targeted country or
SDN. When it comes to OFAC’s attention that an illicit transaction was
processed through a U.S. bank, without being blocked or rejected, as
appropriate, OFAC normally sends an administrative demand for
information, called a “602 letter,” to the bank requesting an explanation
of how the transaction was processed."

Here is the link to the whole doc.
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

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#115835 - 09/19/03 05:57 PM Re: Incoming Wire / OFAC review
Miss Kitty Offline
Platinum Poster
Joined: Mar 2002
Posts: 721
California
Maria -
Thank you!

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#115836 - 09/19/03 06:06 PM Re: Incoming Wire / OFAC review
Retired DQ Offline
10K Club
Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
No problem, Cheryle. Tell the hesitant ones about the Nike commercial: JUST DO IT!
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

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#115837 - 09/19/03 06:31 PM Re: Incoming Wire / OFAC review
Miss Kitty Offline
Platinum Poster
Joined: Mar 2002
Posts: 721
California
LOL - Thank's, I needed that comment. Alot of us here are having a hard time getting motivated since the new's of the merger and the thought that you will soon be unemployed. It's sometimes "hard to comply"...

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