I am being questioned on our current procedures from our new Controller. It is my understanding that we check all parties involved in a transaction so we currently check everyone that is involved with a wire transfer. What I mean is if the wire is being sent to BofA we run an OFAC check on BofA. Am i correct in my thinking?

My FI scans every party, every address, every bank and every notation on the wire.

thanks

........every time!

If you are a small bank checking manually, rather than a bank with an automated system that scans the entire wire, you should be focusing on the beneficiary names, addresses, ship names, country names, foreign bank names, any other names mentioned.

I agree - this will mainly depend on the type of OFAC checking system that you use. If you have an automated system that already checks everything - it is a no-brainer. But if you are doing it manually, carving out domestic Federally insured financial institutions from your OFAC check should be able to be easily justified within your OFAC risk assessment.