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#1189162 - 05/22/09 02:52 PM OFACs missing link! Please try this!
Anonymous
Unregistered

Please, try this OFAC test yourself, and tell us your results with a post in this forum.

1. Regulators, stop reading no fair.
2. Pull the most recent OFAC list from the OFACs website (http://www.ustreas.gov/offices/enforcement/ofac/sdn/index.shtml).
3. On OFACs own most recent list, jump down to around the last 25 pages or so. Look for the section that ends with the word Zimbabwe in brackets, like this: [ZIMBABWE]. Names after Zimbabwe start back in the As again (not the Zs) and all have quotation marks around them, like below.
ZVINAVASHE TRANSPORT
[ZIMBABWE]
"ABD AL-HADI"
"'ABD AL-MUHSI"
"'ABD AL-RAHMAN"
4. Go to your core processor (especially if you are own Jack Henry) and try to perform an OFAC search of several of the names appearing on, roughly, pages 394 to 416. If you get matches on some of them, dont worryjust keep trying. Try at least a dozen and see if you can find some that do not show as matches in your system. In mine, the second name above, "'ABD AL-MUHSI" is no match. Jack Henry assures us that everything is fine. So does IT.

This section is not the PLC list. Our PLC list is already fixed and all show as matches. This section is an alphabetical listing of names in quotation marks that belong to several of the OFAC programs, including, for example: SDGT, SDNT, SDNTK, DRCONGO, etc. etc. etc. On or around page 416, the list changes to Kor., Vessels, etc. I sampled some from each of those last few sections, and they are showing as matches. So its only pages 394 to 416 (approximately).

Again, it is not every name on the list but many, many of them that are not showing as matches.

Does anyone know a valid reason why I would NOT have to check these names? I know no regulation requires checking the names (we just have to avoid doing business with them), but our policy requires checking the OFAC list and I'm uncomfortable with not checking about 5% of it.

Does anyone have an idea how I can correct this? IT, Jack Henry, and my BSA consultants are all drawing a blank.

Thank you!

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#1210224 - 06/30/09 06:37 PM Re: OFACs missing link! Please try this! Anonymous
Anonymous
Unregistered

107 views, 0 replies. Maybe that post was waaay too long. To sum up: There are 20 pages of OFAC hits that do not show as hits in Jack Henry. Do you also have this problem?

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#1210226 - 06/30/09 06:38 PM Re: OFACs missing link! Please try this! Anonymous
Anonymous
Unregistered

P.S. Called OFAC Friday, today is Tuesday - still no reply.

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#1210255 - 06/30/09 07:07 PM Re: OFACs missing link! Please try this! Anonymous
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
I tried five or six, including the one that you did not get a match for, and they all came back as matches. I'm using ITI's OFAC Reporting Module.
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1210260 - 06/30/09 07:12 PM Re: OFACs missing link! Please try this! Kelsey D
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Anon - Is it possible that your shop has not downloaded all info? Also, be sure to check your matching parameters.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

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#1210269 - 06/30/09 07:20 PM Re: OFACs missing link! Please try this! BrendaC
Anonymous
Unregistered

Our shop (IT dept) advises that the weekly or as-needed updates posted on OFAC sites are not complete lists - they are only "updates since the last update" so they contain new names to be added to our list. Seems to me that this means that if we ever skipped a weekly (or periodic) update, we would have missed an entire set of names. But not 20 pages of them, I think, and not all from one heading. This set doesn't even have a heading, it just starts after "zimbabwe" and ends right before the Vessels/Korea section. Hundreds of names, all in quotation marks as though they are aliases. Some of the ones in quotation marks are aliases in Spanish, like "The Ghost" and "The Captain," and stuff like that. Bizarre. Worried about it a bit since it was my auditor that found the problem. And auditors don't have to solve problems; I do.

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#1210272 - 06/30/09 07:22 PM Re: OFACs missing link! Please try this! Anonymous
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Maybe they need to do a full download of the current list to correct the deficiencies.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

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#1210278 - 06/30/09 07:27 PM Re: OFACs missing link! Please try this! BrendaC
Anonymous
Unregistered

That's what I told IT, but their question is, How? IT says not doable. Says they download a ginormous file just to get the weekly updates. That they have never downloaded a full, complete list file. Anyway OFAC's site doesn't have a full, complete file in ASCII format, they say.

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#1210435 - 06/30/09 09:58 PM Re: OFACs missing link! Please try this! Anonymous
First Banker Offline
Gold Star
First Banker
Joined: Apr 2005
Posts: 403
Florida
I think you did the right thing by posting anonymously! I would document every effort and every conversation. I would also consider going over the heads of the persons refusing to run the full file.

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#1211443 - 07/02/09 04:44 PM Re: OFACs missing link! Please try this! First Banker
Anonymous
Unregistered

How do you go over Jack Henry's head?

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#1211503 - 07/02/09 05:30 PM Re: OFACs missing link! Please try this! Anonymous
califgirl Offline
Diamond Poster
califgirl
Joined: Mar 2002
Posts: 2,355
The O.C., California
Well, he's dead.

Did you check with the Regulatory Compliance section at Jack Henry? I wouldn't settle for the answer from the first person who answers the phone.
_________________________
I can explain it to you. I can't understand it for you.

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#1212801 - 07/06/09 03:49 PM Re: OFACs missing link! Please try this! califgirl
Anonymous
Unregistered

Have been trying since 7/2 to get a number for "regulatory compliance at Jack Henry." Contacted them via their website on 7/2 and haven't received a callback. Contacted OFAC 6/26/09, still no callback.

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#1213028 - 07/06/09 06:54 PM Re: OFACs missing link! Please try this! Anonymous
califgirl Offline
Diamond Poster
califgirl
Joined: Mar 2002
Posts: 2,355
The O.C., California
Dennis Gorges
dgorges@jackhenry.com

I don't have a phone number for him.
_________________________
I can explain it to you. I can't understand it for you.

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#1213328 - 07/07/09 02:29 PM Re: OFACs missing link! Please try this! califgirl
Anonymous
Unregistered

Thanks!

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#1216776 - 07/13/09 10:07 PM Re: OFACs missing link! Please try this! Anonymous
Anonymous
Unregistered

If you are ever unhappy with the service/response you are receiving from Jack Henry, contact your bank's assigned Customer Relationship Manager, file a support case at (800) 299 - 4222 and ask to have it escalated, and/or call the manager of Jack Henry's CIF 20/20 support: Steven M. Dodson (417) 235 - 6652 sdodson@jackhenry.com.

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