We'd like to know how often other banks are checking their existing customers against the OFAC list. The hits we received in our most recent check fill about 500 pages. Are you running the list each time the OFAC list is updated or monthly, quarterly?

I am curious to know, too. We do a daily check of wires, new accounts, etc. Then, we run a quarterly check of the entire system. We ran our quarterly check against our entire member base just a couple of weeks ago and came up with the same thing - about a 500 page report. Then, when we had to call OFAC to verify potential matches, they seemed very "put out" to have to check so many names. Apparently a comment was made along the lines of, "Well, if they don't have a foreign address, you don't need to be calling us." I sense that the staff at OFAC is feeling just as overwhelmed as we are by this.

We check our entire customer base quarterly. I'm curious who you use to check your base? We use Thomson Financial and I can set up filters of certain things I don't want them to list as a potential hit. Ex. Ignore middle initials which saves us a lot of names printing on the report.

We do a daily check of wires, new accounts, etc. We check our entire customer file monthly (or whenever names are added to the OFAC list).

I perform the OFAC "scrub" against our crf, mtg loans, employee base, trust account, and securities affiliate when a new update is released. Between times, all new accounts are checked via Chexsystems. Our BSA officer tells me that virtually all hits are on new customers.

I just received some information from Thompson Financial about the OFAC Facfilter. Have you had a good response from using this program?

Thanks

We use Thompson Financial for our "scrub" however with the current updates coming so rapidly, we are looking at purchasing something for our host. Also the control list issued by the regulatory agencies is "confidential" and cannot be given to an outside firm such as Thompson. This actually places us in a position where we must purchase a host OFAC screen. What have all of you done with your control list?

Tina A Sweet-Williams
AVP/Compliance Officer
Gold Country Bank, NA
mailto:tsweet@goldcountrynb.com

Since September 11th, we do every time OFAC updates their list (except when they delete names) or at least monthly if no updates are received. Although they didn't say it, I kinda got the impression from recent examiners that they would like to see it done more like weekly. This may put more burden on many of us than we are able to handle. I have not changed our procedures and don't plan to until I am formally cited by them.

BWest

We run Jack Henry CIF20/20 software and download and run everytime a new list is released. The CIF20/20 software does a daily compare for ACH. We certify the hits and they do not reappear with the next released list and run.

All wires (in and out) are scanned through TFP's "FacLine" product. All new accounts are checked nightly during the update (using the Deluxe "E-Funds" product). Tellers have access to the SDN list for official checks, cash advances, travelers checks, etc and are SUPPOSED to be checking all non-customer activity (including the payees of official checks if non-customer). We are in the process of implementing the "Watchdog" product for our account base. After the initial-run, we'll be scanning quarterly and each time the SDN list is updated.

Control Lists can be provided to your vendor. If you would like to receive the OCC's Q&A document, please e-mail me at markmcc@attustech.com.

How would you rate the WatchDog Software and it's implementation process. I have heard great remarks about the company.

I have no comments yet...we still don't have it "up and running". But we went with the product because it seemed to work the way we needed it to with our software platform (ITI). I'm pretty sure we'll like it.