FRB does not perform OFAC. There is no requirement for your bank to perform OFAC. The only requirement is that you do not enact a payment to/from a person/business/etc. on the OFAC list.
In reality, we perform OFAC scanning on the wires at the point of receipt, prior to accepting and posting to customers accounts. For outgoing, we perform OFAC scanning prior to the wire leaving the bank.
Both processes are done via our wire system, which is the Bankserv/Fundtech GFX platform
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Providing alternative truths since the invention of time