Taking a survey to see if anyone screens buyers of REO properties (they are not clients of the bank).

Thanks

You are still barred from conducting transactions with any persons or entities on the SDN list.

I would conduct the screen.

Please don't confuse OFAC with other BSA regs. like CIP. OFAC laws/regs. have very sharp teeth. It says you cannot deal with listed entities. They don't care whose customer they are/are not. How will you know they are not "listed" if you don't check?

I always remember something I heard at a conference years ago. It was "Flexibility is not an OFAC concept". Under OFAC rules, you don't have to check anything and nobody gets hurt unless you happen to do business with an SDN. You have to determine your risk tolerance when you decide whether to screen or not to screen certain transactions and go from there.

I agree Retread. We do not have a foreign footprint and 99.9% of the payoffs are coming from domestic banks, so I agree that it ought to be a risk based approach.

Let's see, OFAC has somewhere over 95 banks listed, and SDNs in 10 US states. So, what's the problem with screening?

I really hope that you really aren't dealing with selling too many REO properties. As far as the regulators even asking or thinking about it, I think it is a real stretch. Risk - rock bottom low.