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#1614332 - 10/11/11 03:06 PM
Proof of OFAC search
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New Poster
Joined: May 2011
Posts: 13
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We currently print the screen indicating that we have performed an OFAC search for each new account. Is it necessary to print the search results and keep with the signature card?
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#1614346 - 10/11/11 03:24 PM
Re: Proof of OFAC search
sbm70001
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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It's your procedures, not the law, that require an OFAC search be performed. Your procedures can describe what would constitute "proof," starting with initials or a check in a box.
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#1614364 - 10/11/11 03:48 PM
Re: Proof of OFAC search
Elwood P. Dowd
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Member
Joined: Jan 2011
Posts: 74
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Does your OFAC software give you the ability to pull reports as "proof"?
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#1614381 - 10/11/11 04:12 PM
Re: Proof of OFAC search
BSA all the way
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New Poster
Joined: May 2011
Posts: 13
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I'm not sure but I will definitely look into that.
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#1614385 - 10/11/11 04:24 PM
Re: Proof of OFAC search
sbm70001
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Gold Star
Joined: Jun 2005
Posts: 287
Center of US
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Ken is right that your procedures may state the when the OFAC check is done that you mark a box or put a check mark. What I ran into is that is fine if everyone does it. But we had just a few where they either forgot to mark the box or when the examiners ask about an OFAC check they said they did not do it so we ended up having to print off proof of the check for the examiners.
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#1614423 - 10/11/11 06:02 PM
Re: Proof of OFAC search
NLC
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New Poster
Joined: Aug 2009
Posts: 11
Texas
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We used to check a box to show that we did the search, but we ran into the same problem, not everyone was consisitent. So we changed our procedures to keep the print out with the opening account docs. This way we are able to track if one was missed and track the exceptions to follow up on. This made our auditirs and examiners much happier.
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#1614692 - 10/12/11 02:51 PM
Re: Proof of OFAC search
Princess Romeo
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Power Poster
Joined: Jul 2008
Posts: 4,796
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But when you have an automated OFAC system (as most do)it is difficult to turn it off (and more time consuming) for Bank of America, First American Title an any publicly traded companies
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#1614709 - 10/12/11 03:04 PM
Re: Proof of OFAC search
Princess Romeo
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Posts: 4,796
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If it is in their policy and risk assessment it is a requirement eventhouth a waste of time.
If the FI can write a policy that excepts Bank of America and First American Title they can exclued them.
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#1614845 - 10/12/11 05:34 PM
Re: Proof of OFAC search
edAudit
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Power Poster
Joined: Jul 2008
Posts: 4,796
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Back to the orignial question http://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_038.htmTransaction Testing 6. On the basis of a bank’s risk assessment, prior examination reports, and a review of the bank’s audit findings, select the following samples to test the bank’s OFAC compliance program for adequacy, as follows: •Sample new accounts (e.g., deposit, loan, trust, safe deposit, investments, credit cards, and foreign office accounts,) and evaluate the filtering process used to search the OFAC database (e.g., the timing of the search), and documentation maintained evidencing the searches.
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#1616753 - 10/18/11 02:04 PM
Re: Proof of OFAC search
edAudit
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Junior Member
Joined: Feb 2011
Posts: 39
OK
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Our system automatically scans the customer name when we upload the new account. The only time we print anything is if we have a potential "hit". System also does a scan of they entire database every night. We have this in our policy and procedures and have never had a problem with examiners.
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#1623891 - 11/03/11 01:59 PM
Re: Proof of OFAC search
ComplianceAngel
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Platinum Poster
Joined: Jun 2002
Posts: 771
South
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Compliance_angel, what system do you have that runs nightly for your OFAC scan??
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#1624216 - 11/03/11 07:13 PM
Re: Proof of OFAC search
ComplianceAngel
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Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
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Our system automatically scans the customer name when we upload the new account. The only time we print anything is if we have a potential "hit". System also does a scan of they entire database every night. We have this in our policy and procedures and have never had a problem with examiners. We have the same. And, any time OFAC is checked a report is generated with the information that was checked and available for review the following day.
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#1624280 - 11/03/11 08:11 PM
Re: Proof of OFAC search
J2C
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Cheeseheadland
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