I would like to get the group's opinion on this. In an effort to ensure that all employees of a certain department (mortgage) are periodically checked against the OFAC SDN list (new Fannie Mae requirement), is it possible to require that each employee open a checking or savings account? All account holders are regularly checked, and this would ensure that employees are as well. There is only a small percentage of employees who don't already have accounts, but I wondered if there is a prohibition on requiring this of an employee. Thoughts?

I have this same concern and would like to know what others are doing to make sure employees without accounts are checked when the list is updated.

Is it possible to create a CIF record without an account for OFAC scrubbing purposes?

inCompliance, can you provide a link to the new Fannie requirement? I wasn't aware of it.

inCompliance, can you provide a link to the new Fannie requirement? I wasn't aware of it.

Thanks to all for your feedback. I have since been provided with more information and Fannie's new requirement is different than originally thought. It is coming from the Loan Quality Initiative. One of the pieces that will become effective in June is the requirement to validate qualified parties against the GSA list and HUD's LDP list. So to clarify, they are not asking for the OFAC list to be checked. They're leaving that to the Patriot Act. However, this is not an easy requirement because we will need to run the names of our staff through the LDP and GSA lists. At least with OFAC, we have that check in place for other requirements and we could piggyback an existing process. Unfortunately, this is another new process... The link to Fannie's Loan Quality Initiative page: https://www.efanniemae.com/sf/lqi/index.jsp

Thanks very much for the information.

I thought this was already a requirement.

Some teller systems have the ability to create a name/address file record that will be subject to OFAC scanning nightly. If you are involved with any aspect of managing your CTR process, you need to get very well acquainted with your teller system. Don't rely on current teller process - identify system capabilities.