Our customer had been in a few times looking for an incoming wire. He said it was sent 2X but rejected. It never showed up on our end. When asked for further info about the wire, he was vague in his answers and said it was coming from somewhere in Europe and it would be used for business purposes. A week later, he came in again checking on the status and after asking more questions, he said it was coming from Iran. The wire eventually came in but from a trading company in the UAE. It cleared all OFAC checks. Our concern is that the remitter may have tried to circumvent the sanctions program if indeed it did come from Iran.

If you belive it was from Iran, and this is what the customer told you - I would file a SAR.

If you want to take it futher and the customer has not taken the money out yet - Call OFAC and ask them what they want you to do with the money.

I'll second BC78a here. Hold the funds and file the SAR. Your situation seems similar to in some ways to Trans Pacific National Bank, who were penalized for indirect transactions eventually involving Iran. OFAC has penalized other entities under similar circumstances:

http://www.treasury.gov/resource-center/sanctions/CivPen/Pages/civpen-index2.aspx

It is legal in the Emirates for a trading company established in the Emirates to have up to 50% Iranian ownership. It's good to ask for some additional details, but as others have noted, the customer's self-disclosure wins the suspicion lottery.

I have a similar situation.

My customer said he's going to try sending his wire to Canada first, and then have it wired to his account in the states.

Just to confirm, we shouldn't knowingly receive a wire from an OFAC sanctioned country, directly or indirectly?

Whether you grab the funds or reject the transaction depends on the SDN involved and the applicable restrictions. (You did not say where it was coming from.) Your bank's problem might resolve itself if you make certain your customer is aware of the restrictions and, thus, exactly what will happen to this payment upon its receipt at your bank.

As noted, your customer may have already won the SAR lottery.

The wire is coming from Iran and he says it's inheritance money ($80,000). The wire was rejected once already.

I have to be honest about this. You are playing with fire either way. Who is the originating party? How sure are you that the originator isn’t on the SDN List? Even if they're not, how can you possibly document that from an EDD perspective?

From what I recall, the Iran sanctions were mostly prohibited. So, it appears that you have already handled it appropriately by rejecting the wire. However, given all the recent updates to the Iranian and NPWMD Sanctions, I would clear any transaction directly with OFAC prior to accepting the wire.

I called OFAC. They said personal remittances to and from Iran do not have to be rejected as long as the Iranian bank processing the wire is not on the SDN list. *Most Iranian banks are on SDN list.

If OFAC cleared the transaction, I would assume it's okay to process it then. I would monitor the account(s) and see what the customer does with the funds. Documentation will be key.

I agree. I'm going to make sure we have a timeline and as much documentation as possible in case this gets flagged by an examiner or auditor.

Prio to calling OFAC, I would have assumed the transfer should be rejected...You learn something new everyday.