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#130713 - 11/13/03 10:11 PM OFAC sort of - DTC List
Michelle D Offline
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Michelle D
Joined: Oct 2001
Posts: 313
Terminator Country
We use the full Bridger system and we had a customer appear as a "100%" hit on the State Department's DTC list. Unfortunately the customer has a common name, so it may be a false positive.

In researching the information, the State Department website says to refer to the Federal Register where the name appeared. The problem is that the Federal Registers are from August and September of 1992 - they're not online anymore, and I certainly don't have hard copies

Does anyone have any suggestions on how to continue this research project.

Thanks for you help
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#130714 - 11/13/03 10:34 PM Re: OFAC sort of - DTC List
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Those common names can be so frustrating on that OFAC list! A few of the things I look at:
1. Does the customer have an interest bearing account, and do we have any outstanding "B" notices? If the name and SSN have been okay with the IRS, and the SSN does NOT appear on the OFAC list, then I'll take that as an indication that it is likely to be a false positive.

2. Is the customer's address in the U.S.? If so, how long has the customer been at their current address? If they've been at a U.S. address for more than a couple of years, then it is likely to be a false positive.

3. Did you get an in-state Driver's License on the customer, or did you use a passport? If you obtained an in-state Driver's License, and your staff is reasonably certain it was genuine, then I would say it is likely you have a false positive.

The only way to be really certain, I suppose, is to call OFAC and send them the identity information you have. However, from my past experience, OFAC was not too thrilled with me when I called with 5 different Carlos Gonzales's.

As I recall, my query was met with a reponse something along the lines of "Oh honestly - do YOU think these people are the same as the OFAC list?
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#130715 - 11/13/03 10:39 PM Re: OFAC sort of - DTC List
Michelle D Offline
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Michelle D
Joined: Oct 2001
Posts: 313
Terminator Country
Already went down that path, the unfortunate thing is that the DTC list isn't the OFAC list and there's no one at the state department to call.

The DTC list doesn't shut down the customer necessarily, just prevents certain activities, in this case "import/export". As I said before, we can't get the detail because it was in the 1992 Federal Register and no one has those anymore.

Just wondering if anyone else was having these issues.

Thanks
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#130716 - 11/14/03 03:35 PM Re: OFAC sort of - DTC List
Retread Offline
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Retread
Joined: Oct 2003
Posts: 2,548
Southeast
Michele,
Go to http://www.fas.org/irp/threat/terror_92/
Scroll down to Appendix B. It isn't the FR, but it may give you some clue of what they are talking about. Also, if you click on "Terrorism Resources" at the top of the page, you can find some other "terrorist" information.
Good Luck.
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