Skip to content
BOL Conferences
Thread Options
#1797519 - 03/22/13 01:43 PM OFAC on non-customers
Burgess Offline
Diamond Poster
Joined: Jan 2004
Posts: 1,621
Has OFAC passed us by?

we have always CIP'd non-customers that have cashed our customers on-us checks here at the bank (we don't cash checks not drawn on us for non-customers). We have not gone out and run OFAC on them. We have always been fine on exams. I am hearing though that OFAC is becoming a issue here.

What do others do/think?

(same question as above - non-customer signers on our church accounts - we CIP them but have never ran OFAC)
_________________________
My views, not my employer's views.

Return to Top
BSA/AML/CIP/OFAC Forum
#1797522 - 03/22/13 01:50 PM Re: OFAC on non-customers Burgess
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
OFAC is a risk based decision. Some banks do, some banks don't. It depends on their risk profile and risk assessments.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1797572 - 03/22/13 03:15 PM Re: OFAC on non-customers Burgess
NotDoneYet Offline
Gold Star
NotDoneYet
Joined: Jul 2010
Posts: 482
PA
I agree with rlcarey.
Our Bank's policy identifies when we run an OFAC and we are held to that standard during exams. OFAC doesn't require a search, but don't do business with someone on it so its a risk decision.

Return to Top

Moderator:  Andy_Z