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#1787936 - 02/21/13 03:37 PM OFAC - Questionable Instances
ComplianceNerd Offline
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Joined: Nov 2011
Posts: 378
Texas ...
Just curious, would it be proper to pull OFAC on a borrower who is joining "Proforma".

What about someone who is pledging their collateral through a hypothecation agreement?
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#1787940 - 02/21/13 03:41 PM Re: OFAC - Questionable Instances ComplianceNerd
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
OFAC compliance; i.e. checking the list, is risk based and depends on the individual bank's risk assessment. There is no legal requirement to check the OFAC list under any circumstance.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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