When checking new customers against the OFAC list, are we to be checking all titleholders of the account or all signers of the account? In a case of a corporation with six signers, we check the WDFI (WI Department of Financial Institutions) website to check the corporation or LLC's "status". If they are in "good standing" we assume that the DFI has checked the corp. against the OFAC list. My question really lies with the signers - do we need to check each individual signer? We currently do not add all signers to the titles or our database. We refer to the resolution when identifying authority to do transactions because the signers may change frequently. We may only have their names and no other information to cross reference a possible match. Thank you!!

First of all, do you have a piece in your CIP about relying on other sources for the OFAC check? If you are relying on the DFI to have checked the status, you are relying on another source. Second item, we do an OFAC check for business names on the OFAC website and our individual signers, we have a credit report, the OFAC check is done through Trans Union and reported on the credit report. This covers us for both the business and the individual. If we do not pull credit reports on all signers, then we have the option of using the OFAC website on those individuals. We just print out these documents off the website and keep in their files.