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#1843164 - 08/16/13 03:30 PM OFAC Screening REO buyers
loyo111 Offline
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Joined: Mar 2006
Posts: 102
Miami
Taking a survey to see if anyone screens buyers of REO properties (they are not clients of the bank).

Thanks

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BSA/AML/CIP/OFAC Forum
#1844128 - 08/20/13 05:01 PM Re: OFAC Screening REO buyers loyo111
James M. Moore Offline
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James M. Moore
Joined: Jul 2013
Posts: 110
Georgia
You are still barred from conducting transactions with any persons or entities on the SDN list.

I would conduct the screen.
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#1844284 - 08/20/13 08:06 PM Re: OFAC Screening REO buyers loyo111
Just Jean Offline
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Joined: Feb 2002
Posts: 582
USA
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?

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#1844356 - 08/21/13 12:47 AM Re: OFAC Screening REO buyers Just Jean
Retread Offline
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Retread
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Posts: 2,548
Southeast
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.
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#1848017 - 08/30/13 08:57 PM Re: OFAC Screening REO buyers loyo111
loyo111 Offline
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Joined: Mar 2006
Posts: 102
Miami
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.

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#1848020 - 08/30/13 09:02 PM Re: OFAC Screening REO buyers loyo111
Xian Ngyuen Offline
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Joined: Aug 2013
Posts: 221
Originally Posted By: loyo111
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?

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#1848028 - 08/30/13 09:31 PM Re: OFAC Screening REO buyers loyo111
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
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.
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