Sorry, but I am unable to locate information on the following. If you have a match for a loan customer what is the banks requirement as far as accepting future payments, paying of taxs and insurance if escrowed? Must we hold all funds and must it be interest bearing like deposits?

I believe this is an instance where you should call OFAC's Compliance Programs Division at 202/622-2490 for assistance. 1. You need to be sure your customer is in fact an SDN, and 2. you need specific guidance on your situation since the rules are different depending on the nature of the sanction that applies to your customer.

I agree with Retread.

You may want to see which of the OFAC sanctions that the borrower falls under, as there are different requirements for each. Additionally, and depending on the OFAC program, you may want to consider making the tax or insurance payments potentially to prevent loss of your collateral in the interim.