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#1314241 - 12/28/09 10:32 PM OFAC - periodic database comparison to SDN
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
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Our core processor recently added an OFAC checking capability to the system. It allows us to download the current SDN and then match the core processor database (loans, deposits, safe deposit boxes and customer information files) against the SDN. It identifies possible matches based on a phonetic comparison. It then gives us the ability to 'exempt' that customer/account from further matching (i.e., it won't appear on the match list any longer). As I understand it, when a new SDN is downloaded, those 'exempt' customers won't be matched any longer, as presumably we know who they are.

However, I am concerned that there is a small chance (very small considering our customer base) that an existing customer could get added to the SDN in the future and we may not catch it.

Are other OFAC-checking mechanisms working this same way? If not, how do they manage the comparison?

You can alwys PM me as well.
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BSA/AML/CIP/OFAC Forum
#1314257 - 12/28/09 10:41 PM Re: OFAC - periodic database comparison to SDN Doug Hendrickson
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
My FI is currently using Banker's Toolbox BSA Manager. As I understand it, an exempted person/entity will be checked against an updated OFAC list.

While the chances that a customer will appear on the OFAC list after you exempt them are small, it is still a possiblity. Your OFAC RA should decide how you proceed.
Last edited by ACBbank; 12/28/09 10:42 PM.
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#1314551 - 12/29/09 06:01 PM Re: OFAC - periodic database comparison to SDN ACBbank
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
We use Global Vision's Patriot Officer. A update, current CI file is uploaded into PO every day. PO monitors the OFAC website - when an update occurs, PO automatically conducts a new complete search for us and we check the results.
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#1314570 - 12/29/09 06:30 PM Re: OFAC - periodic database comparison to SDN CantBeShocked
Doug Hendrickson Offline
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Doug Hendrickson
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Thanks. I'm not sure how many 'false positives' you both have been getting, but for us it was a lot! However, in reviewing the report, most of the 'false positives' were matches to vessel names. I've asked the vendor to only match against INDIVIDUALS and ENTITIES so as to drastically cut down on them.
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#1314588 - 12/29/09 06:44 PM Re: OFAC - periodic database comparison to SDN Doug Hendrickson
Bobw Offline
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Bobw
Joined: Nov 2006
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New England
I would guess it is your call and what you have on your risk assessment, but I would not risk someone I exempted being added to the list and missing it. The OFAC rules are very basis as it says basically "thou shall not do business with anyone or group or country on the OFAC list.
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#1315136 - 12/30/09 03:00 PM Re: OFAC - periodic database comparison to SDN Bobw
Doug Hendrickson Offline
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Doug Hendrickson
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Is anyone else having a lot of 'false positives' being generated due to the match on Vessels?

Even when I raised the phonetic key to a higher number I'm still getting 4,000+ matches.

I'd appreciate any other feedback from those of you that did the initial CIF-OFAC match up.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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