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#1888892 - 01/22/14 02:16 PM OFAC Screening - Incoming Wires - Sender Info
yy2say Offline
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yy2say
Joined: Apr 2002
Posts: 279
PA
What are the requirements under OFAC when accepting domestic wires for customers only? Are we required to screen the originating financial institution(s) and the sender?
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BSA/AML/CIP/OFAC Forum
#1888897 - 01/22/14 02:22 PM Re: OFAC Screening - Incoming Wires - Sender Info yy2say
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
There are no OFAC requirements. It is all based on your determined risk that the other person or financial institution may be on the OFAC list.
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#1888915 - 01/22/14 02:43 PM Re: OFAC Screening - Incoming Wires - Sender Info yy2say
Xian Ngyuen Offline
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That's not really true. There are quite specific OFAC requirements for handling transactions involving listed/blocked entities.

An institution can determine that a wire transfer at hand contains no listed entity definitively by scanning against the appropriate sanctions lists. Or, an institution can simply express its belief that the transaction doesn't contain any listed entity.

How it comes by that belief should be an interesting exercise.

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#1888919 - 01/22/14 02:48 PM Re: OFAC Screening - Incoming Wires - Sender Info yy2say
rlcarey Offline
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rlcarey
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Galveston, TX
Bottom line? There is no regulatory requirement to check anything. It is all based on perceived risk that a bank wants to take. If there is, show me a citation.
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#1888930 - 01/22/14 02:54 PM Re: OFAC Screening - Incoming Wires - Sender Info yy2say
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,437
Illinois
The takeaway from the responses above is this:

OFAC prohbits you from doing business with any entity on the SDN list. It does not prescribe a course of action for how you avoid doing business with any of these entities.

So the answer to "Are we required to screen..." is "No"

The answer to "Should we screen" as Randy says is based on your risk assessment. Since wires are a higher risk transaction, Ed recommends as a wise risk mitigant. (I agree). So we would answer "Should we screen..." as yes.

You could choose not to because you trust that the originating bank screened their customer already...but suppose that they didn't or the originator wasn't a customer and the bank accepted a cash wire and someone missed a step...

My automated system screens the originator, the originating bank and any intermediaries in between because my risk tolerance non-existant.
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#1888938 - 01/22/14 02:59 PM Re: OFAC Screening - Incoming Wires - Sender Info yy2say
Xian Ngyuen Offline
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Thank you, Brian.

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#1890044 - 01/24/14 04:51 PM Re: OFAC Screening - Incoming Wires - Sender Info yy2say
yy2say Offline
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yy2say
Joined: Apr 2002
Posts: 279
PA
Thank you all. Happy Friday!
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