So now, aside from the SDN, Non-SDN, PLC list we have a new list to scrub against - the Sectoral Sanctions Identification List? Is this correct?

OFAC press release from yesterday.

The short answer is "yes". The longer answer is to check with your list provider to see if they plan to bundle the SSI list in with all the other non-SDN lists.

After contacting OFAC it seems they are not, at the present time, creating a list similar to that of the SDN or FSE which could be uploaded into a system. They are presently staying with the PDF and text files. Great!!!

To confirm I've got this straight, the SSI List in itself is not a 'blocking' action (though if the same name appears on the SDN List it would be blocked) but you're prohibited from "transacting in, providing financing for, or otherwise dealing in" new debt with over 90 day maturity or any new equity for the individuals, their property, or their interests.

From a bank standpoint, we're probably only going to be concerned with the 'debt' portion - so you could allow them to open a checking account but need to bounce the SSI List on a request for all new loans greater than 90 days?

So even if it could be uploaded/automated, we'd need some pretty specific parameters to get it to catch vs. ignore the various scenarios.

That's the way we are reading it too. That it would only relate to lending. We use Fiserv and since they can't add the FSE list to the SDN checks, every morning I manually plug in the names on the list to verify they are not uploaded in our system for a new account. Looks like I will be doing the same for the SSI list. The only problem is, some of the names are so long on the list if we enter them in our system, we will only get an error message that the name is too long. How are we supposed to check these names in this case?

Don't forget about the 311 List (regulators starting asking about this last year) and Part 561 List (found this yesterday)

OMG - Part 561 list? Where has this been? (I see the date of May 2013, but don't remember ever seeing it before.)

So let's recap - In addition to the SDN list, is there a concise place to locate links to all the other OFAC "lists" that (depending on the risk profile of the bank of course) may require scanning before account opening or conducting a transaction (like a wire or IAT?). OFAC's page under financial sanctions doesn't even mention PLC or the Part 561 list.

OFAC:
SDN
PLC
Foreign Sanctions Evaders
Sectoral Sanctions
Part 561 List

And, it's not OFAC, but just because I'm listing lists.....
FinCEN:
311 Special Measures list (maybe?)

Any others?

You regulator may wish to see an internal "blacklist" and how you review it.

I came across the 561 yesterday when trying to pull the 311. In all the training I've particpated in, I have never been told about the 561. My staff tests our core system and BSA software with a sample from each list when they are updated. We had/continue to find major descrepencies with results from our cores OFAC module.

I've checked into all our various vendors to see who includes what lists, and the only vendors including all are the BSA software vendors. It's unnerving to say the least... Especially since a well know core vendor can't figure out how to incorporate all of them.

We were encouraged by our regulator to use an outside vendor rather than our core vender for OFAC.

Perhaps it is not a big deal having separate 561 and SSI lists because for 561 we are only prohibited from opening a correspeondent or payable through account for the banks on the list (how many of us would be opening an account for a Chinese bank anyway?) and for SSI we are prohibited from financing, not for other transactions.

One thing to keep in mind with the SSI list is that the 50% rule still applies; and you will have to list those entities, too.

Quite a few of us and the Money Center banks

IMO, It should be mandated by the US Gov't that the vendors which we FI's rely on for screening gov't lists include any/all lists of persons/entities etc., who have any type of financial restrictions or pose additional risk to our US Financial System.

IMO, that should be demanded by the users and if the vendors don't comply, then you stop using their product. The gummint should stay out of it, except to publish the list. (I do think, however, the gummint should maybe come up with ONE or maybe even two lists, instead of creating new and exciting lists every time they think of something.)

Just incase some of you guys don't get notifications of updates to the SSI List there was an update yesterday.

No - it should be mandated that the US Gov't issue and maintain the lists in a UNIFORM FORMAT that allows the lists to be electronically incorporated into screening software. That, and there should just be ONE LIST with a descriptor field that indicates which sanction applies and what action is to be taken in the event of a positive match.

If banks ran their systems in the manner that the U.S. Gov't does, we would be facing a massive C&D and penalties for UDAAP.

^^^^ What she said!

We use Accuity for the SDN list but they will only provide a separate SSI list and it is at an extra cost. My understanding of the SSI sanctions is that they prohibit financing but not other transactions. We are a community bank that would never in a billion years finance any entity on the list so my plan is to not pay Accuity the extra subscription fee and not modify our system to import another list. Can anyone poke a hole in this plan?

Then how would they issue a MOU for not complying?

Yes

Do you have a written policy that states that you will not? (remember that the lists (and reasoning for the lists) can change)

Fiesty....lol I was simply saying we pay for a service from vendors, seems as though most are not "up to par". But I totally agree that if the govt could provide 1 list, that would be key!