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#1219781 - 07/21/09 03:27 PM OFAC POLICY INCLUDING IAT
Auditor9 Offline
Member
Joined: Jun 2008
Posts: 73
UPSTATE
Has anyone seen or updated their OFAC policy to include the new IAT rules which is to begin in September 2009?? Any one care to share a policy or know where to find a sample.

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eBanking / Technology
#1231121 - 08/11/09 07:28 PM Re: OFAC POLICY INCLUDING IAT Auditor9
ComplianceGurl, CRCM Offline
Gold Star
Joined: Jul 2007
Posts: 498
Ditto here! I would greatly appreciate it if someone had something to share.
Thank you!!

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#1231222 - 08/11/09 08:59 PM Re: OFAC POLICY INCLUDING IAT ComplianceGurl, CRCM
bsarockstar Offline
Junior Member
Joined: Aug 2009
Posts: 32
We added the IAT information to our OFAC Policy. It is about three paragraphs long: the first one explains what an IAT is which we "took" from NACHA. The second paragraph explains that we are an RDFI and that we will review all parties involved in the transaction. We stated that at this time we are not an ODFI but if we were, we would review all parties and remittance data. Then in the last paragraph we explained what our processor will be giving us and how we use Bridger to check all parties. Documention procedures and retaining is also included.

We didn't need to add if and OFAC name appeared since it was already in our policy. Any findings, whether it's a wire or a new loan customer, has the same policy/procedure.

Hope this helps a little smile We know that we may have to revise ours once we know what to expect.

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#1231337 - 08/12/09 12:37 PM Re: OFAC POLICY INCLUDING IAT bsarockstar
ComplianceGurl, CRCM Offline
Gold Star
Joined: Jul 2007
Posts: 498
That does help! Thanks bsarockstar!

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