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#1889012 - 01/22/14 04:38 PM OFAC - Non-customers
newbietoo Offline
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Joined: Aug 2009
Posts: 201
I hate to start a new thread, but do any of you do OFAC checks on non-customers? If you do, is it written into your policy? Do you describe what non-customer transactions require it?

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#1889020 - 01/22/14 04:57 PM Re: OFAC - Non-customers newbietoo
Xian Ngyuen Offline
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Joined: Aug 2013
Posts: 221
One example where we would do sanctions checking (OFAC plus other pertinent lists) on non-customers would be in the area of trade finance, where we would screen agents, insurers, intermediary parties, 3rd party payees, vessels, ports and so on.

Another is wire transfers processed on behalf of correspondent banks; the originating party and beneficiary parties would not be our customers, rather they are our customer's (the correspondent bank) customer.

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#1889176 - 01/22/14 08:30 PM Re: OFAC - Non-customers newbietoo
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
We also run OFAC on Cashier Check payees.

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#1890462 - 01/25/14 05:02 PM Re: OFAC - Non-customers MagicCity
Cape Codder Offline
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Joined: Jul 2011
Posts: 413
Bill Pay payees - yes
Accounts Payable vendor payees - yes
Non-customer payees on loan disbursements - yes
Non-customer treasurer's check payees - yes (with threshold)
Non-customer cash advances - yes (with threshold)
Non-customer payees cashing on-us checks - no, with reasons why documented in our BSA Risk Assessment
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#2067401 - 03/03/16 07:41 PM Re: OFAC - Non-customers newbietoo
banker1976 Offline
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Joined: Nov 2005
Posts: 342
Mid-Atlantic
Just curious, Cape Codder, if you would share some of the reasons in your Risk Assessment for not checking OFAC on non-customer payees cashing on-us checks (we're updating our policy and are just curious as to verbiage others are using).
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#2067403 - 03/03/16 07:51 PM Re: OFAC - Non-customers banker1976
Cape Codder Offline
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Joined: Jul 2011
Posts: 413
It would require a manual search of the OFAC Search Tool on each non-customer payee name, the cost of which would outweigh the risk. Risk is mitigated by our limited geographic footprint.
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