Currently we screen our new vendors prior to issuing any payment to them. However our auditors, in their interpretation of FFIEC, said we should be screening them before we even have a relationship with them, before they do any work for us instead of waiting until they have done their work and we are ready to make a payment. This would be much in the same way we would screen our new customers, up front before any money exchanges hands. We would continue to screen each existing vendor before making a payment. Does anybody have this issue? How are you screening your vendors currently?

I would think that your auditors would have better things to do. What is the chance that one of your vendors would ever be on the OFAC list, unless you contract with a lot of foriegn companies? I can tell you - zilch. I would be surprised if a risk assessment would even deem it worthwhile, unless the OFAC check was automatically built into your accounts payable process.

It is common to screen up front and periodically - maybe semi-annually or annually. I don't know any bank that screens with each transaction.