During an OFAC compliance audit, a name from the OFAC list was submitted to eFunds in order to analyze eFunds success prohibiting account opening. The name was submitted exactly as shown on the list. eFunds failed to notify the bank that the customer's name was on a government list. How could this happen?

The name may have been recently added to the OFAC list and eFunds had not updated their lists.

I would be asking eFunds that very question.

I guess that is a possibility. Perhaps eFunds doesn't update every day.

It also may depend on how the name was entered and how eFunds recognizes it. I have found that variations of spelling (Mohamed vs Mohammed) and the order in which you enter the name (Last, First or First Last) can make a difference in whether the system picks it up. You'll have to get more details on how they actually work the list.

I think the OP said the name was entered exactly as it appears on the SDN list.

This is why we don't rely on E-Funds for our OFAC verification for new accounts, we run the name through Watchdog.

We don't use Efunds for OFAC verification either, we use Watch Dog. However, I believe that Efunds put out a memo a few years ago that said they OFAC scrub the night you do your search and the government list comparisons would be available on the next business day. I'd check my archived/historical reports today and double check it. But, I'm pretty sure that I remember that being the case.

Check with eFunds what your confidence level is. That will have a major impact on your results. What name did you use for testing?

FIS discontinued the next day ChexSystems OFAC service as of November 30, 2013.