A year or so ago it seemed to be common practice to OFAC screen your existing accounts file once a quarter, and then only deposit accounts. With all the events since 9/11, and the constant changes to the OFAC list it seems the old practice of quarterly screening is out of date. I'd just like to know what everyone else is doing now regarding portfolio screening. Are you screening more often? Monthly? Everytime the list changes?
I know this is a highly subjective, risk based topic, but I'd still like to have an idea of what everyone is doing if you don't mind sharing.