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#157678 - 02/06/04 03:47 PM Incoming Wires and OFAC
MDR Offline
New Poster
MDR
Joined: Feb 2004
Posts: 13
Oklahoma
As the recieving bank of an incoming wire, are we responsible for checking OFAC against the sender or are we able to rely upon the sending FI?

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BSA/AML/CIP/OFAC Forum
#157679 - 02/06/04 03:57 PM Re: Incoming Wires and OFAC
ABirkla Offline
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ABirkla
Joined: May 2002
Posts: 103
Our procedure is to verify the originator and the beneficiary for incoming and outgoing.
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#157680 - 02/06/04 04:34 PM Re: Incoming Wires and OFAC
Anonymous
Unregistered

You can rely on the sending FI if you want to, but if the name is on the SDN list, you are both in trouble. Them for sending it, and you for receiving it.

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#157681 - 02/06/04 04:51 PM Re: Incoming Wires and OFAC
Retired DQ Offline
10K Club
Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
Quote:

Our procedure is to verify the originator and the beneficiary for incoming and outgoing.



Ditto.
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Get your facts first, then you can distort them as you please. - Mark Twain

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#157682 - 02/06/04 06:13 PM Re: Incoming Wires and OFAC
Kansayaku Offline
Diamond Poster
Joined: Jan 2003
Posts: 1,454
metsuretsu
The funny thing about OFAC is that you are technically "responsible" for everything that you do that could potentially come into contact with one of the listed entities, countries, or individuals. Considering that, your institution has to determine how much risk it is willing to take based on the cost of decreasing and hopefully eliminating that risk.

Where wire transfers are concerned, most financial institutions I have talked to have generally checked the names regardless of whether they were an originator, intermediary or beneficiary.
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#157683 - 02/06/04 08:28 PM Re: Incoming Wires and OFAC
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Quote:

Where wire transfers are concerned, most financial institutions I have talked to have generally checked the names regardless of whether they were an originator, intermediary or beneficiary.




I agree! Too serious a topic to do otherwise...

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#157684 - 02/10/04 03:13 PM Re: Incoming Wires and OFAC
skinnyminny Offline
Gold Star
skinnyminny
Joined: Mar 2002
Posts: 395
Heaven in comparison to my pri...
Don't rely on someone else. Do it yourself. As the other responses indicate-many banks have been in trouble for relying on others to check OFAC.

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#157685 - 02/13/04 04:50 PM Re: Incoming Wires and OFAC
Ucan'tdothat Offline
Member
Ucan'tdothat
Joined: Feb 2004
Posts: 92
Miami
If you are using software for OFAC compliance in wires, you may consider running it against the meesage/instructions section of the wire order as well. We find, from time time, references in the instructions that the payment has to do with Cuba or Cuban Nationals.

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