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#1930620 - 06/09/14 02:28 PM OFAC scan frequency
Trees Offline
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For Community banks (versus multi-nationals: how often do you run your OFAC software against your account database? Once per month, weekly, every time there is an OFAC update?

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BSA/AML/CIP/OFAC Forum
#1930622 - 06/09/14 02:28 PM Re: OFAC scan frequency Trees
Little Miss BSA Offline
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Little Miss BSA
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Miami
We run it nightly.
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#1930629 - 06/09/14 02:45 PM Re: OFAC scan frequency Trees
MagicCity Offline

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MagicCity
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Fort Lauderdale, Florida
We run nightly also.

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#1930661 - 06/09/14 03:38 PM Re: OFAC scan frequency Trees
Doug Hendrickson Offline
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Doug Hendrickson
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We run it weekly, and whenever the SDN is updated. We also do OFAC on account opening (Loans-Transunion;Deposits-FIS) so anything new is covered.

We used to do it nightly, but given the fact that we've never had a true positive the risk didn't seem to be there to have to run/check it daily, which I viewed as overkill.
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#1930677 - 06/09/14 04:18 PM Re: OFAC scan frequency Trees
SUSA Offline
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USA
We run monthly.
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#1930681 - 06/09/14 04:28 PM Re: OFAC scan frequency Trees
JWills, CRCM Offline
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JWills, CRCM
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The Mitten State
Ours runs nightly and also if the SDN list changes.
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#1930685 - 06/09/14 04:35 PM Re: OFAC scan frequency Trees
Xian Ngyuen Offline
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Posts: 221
Doug, do you also run it when account details change (name, address, related parties)?

Running "whenever the SDN changes" implies that you will run it on consecutive days, or even multiple times in a day (since both things have occurred.) The last time I calculated the mean time between list updates it was 3 days.

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#1930700 - 06/09/14 05:13 PM Re: OFAC scan frequency Trees
Sherlocked Offline
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221B Baker St.
Monthly and when SDN list changes.
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#1930843 - 06/09/14 08:27 PM Re: OFAC scan frequency Trees
NotDoneYet Offline
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NotDoneYet
Joined: Jul 2010
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PA
Whenever a new person or entity is added to the system, the CSR runs them through an OFAC check. The system is scrubbed whenever there is a change to the list.

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#1930884 - 06/09/14 09:32 PM Re: OFAC scan frequency NotDoneYet
Cape Codder Offline
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All new customer relationships are run nightly; entire customer database is scrubbed monthly and also whenever there are changes to SDN list.
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#1930888 - 06/09/14 09:50 PM Re: OFAC scan frequency Xian Ngyuen
Doug Hendrickson Offline
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Doug Hendrickson
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I would run it on consecutive days, or even multiple times per day, only because that's what we say in our policy. It is something I've considered changing.

We generally do NOT run it when account details change (other than the addition of a new owner).
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1931117 - 06/10/14 06:06 PM Re: OFAC scan frequency Trees
summergirl Offline
Member
Joined: Jul 2009
Posts: 52
Delaware
All new customer relationships are run nightly; entire customer database is scrubbed whenever there are changes to SDN list.

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#1931880 - 06/12/14 03:20 PM Re: OFAC scan frequency Trees
Mbank Offline
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Mbank
Joined: Oct 2012
Posts: 33
MS
New customers we check on account opening, the entire database is done every night.

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#1933305 - 06/17/14 06:52 PM Re: OFAC scan frequency Trees
J2C Offline
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Posts: 1,475
Big Brother knows and that's a...
Trees-- your core may have a process.... you should check with them. My guess is that it is nightly and a full scan is done when OFAC is updated.
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#1933322 - 06/17/14 07:16 PM Re: OFAC scan frequency Trees
Sunshine Lady Offline
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Our entire data base is run nightly.
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#1933327 - 06/17/14 07:19 PM Re: OFAC scan frequency Trees
Beachbum, CRCM Offline
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Joined: Dec 2006
Posts: 480
Knee Deep in Regs
Same as MBank, New customers checked at Account opening, Full Scan Nightly.
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#1933333 - 06/17/14 07:37 PM Re: OFAC scan frequency Trees
newbietoo Offline
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Joined: Aug 2009
Posts: 201
Nightly, whole database monthly and also when there are changes to the SDN list and certain changes to customer data.

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