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#1959441 - 09/04/14 07:24 PM 314(a) OFAC and ACH
Piano Man Offline
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Piano Man
Joined: Mar 2004
Posts: 442
Down South
We are beginning the process to originate ACH. I have looked at the 314(a) instructions and did not see where we have to search a customer's ACH file for individuals/businesses listed in the 314(a) request. Is this correct? OFAC is required though?
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#1959503 - 09/04/14 08:54 PM Re: 314(a) OFAC and ACH Piano Man
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
You perform 314a searches on your accounts so you need not search the originated ACH transactions since you would only originate for your account-holders. What I am trying to say is that you would not search on the beneficiaries of the transactions since they are customers of the receiving bank and they would need to search. I hope this is clear.

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#1959578 - 09/05/14 01:37 PM Re: 314(a) OFAC and ACH Piano Man
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
If you log into the secured site, there is a FAQ which defines transactions which are required to be screened for 314a compliance. It's been a while since I reviewed it, but I believe Devs is correct in that ACH does not need to be screened.

You're not required to scan any party against OFAC's SDN List. OFAC screening is risk based and your OFAC RA or other appropriate document should detail who and how you will screen.
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#1960227 - 09/08/14 09:47 PM Re: 314(a) OFAC and ACH Piano Man
PeeWee Offline
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Joined: Aug 2007
Posts: 254
Piano Man, I'd also recommend searching the online FFIEC BSA Exam manual using the search term "batch". That will take you directly to the section that discusses originated files as they relate to files that are batched that the FI may unbatch.

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