Skip to content
GeoDataVision
Thread Options
#1969797 - 10/16/14 03:24 PM OFAC screening on domestic banks
Sisyphus Offline
100 Club
Sisyphus
Joined: Jun 2008
Posts: 222
Is it common to perform OFAC screening when the receiving bank or an intermediary bank is a domestic bank?

Return to Top
BSA/AML/CIP/OFAC Forum
#1969864 - 10/16/14 04:39 PM Re: OFAC screening on domestic banks Sisyphus
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,935
Galveston, TX
Most systems automatically screen everyone involved with a wire, so yes.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1969899 - 10/16/14 05:19 PM Re: OFAC screening on domestic banks Sisyphus
CULady Offline
Gold Star
Joined: Sep 2007
Posts: 495
WA
For us it is a manual process. But we do OFAC domestic banks. We went back and forth with the NCUA and it just became easier to OFAC everyone every time. If I can make out a name/business I OFAC it. Better safe than sorry and I am already in there OFACing other things anyway.

Return to Top
#1969926 - 10/16/14 05:50 PM Re: OFAC screening on domestic banks Sisyphus
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
(shakes head).... I sure hope you run the National Credit Union Administration through OFAC every time you need to send a remittance to them.

It's one thing to have an automated system that screens all fields. It's quite another to require a MANUAL screen every time you need to send a wire to Bank of America. OFAC does NOT require that, and your OFAC program should be risked based.

But if that's how your NCUA examiner wants to play, then I would suggest that, before you allow them to plug in their laptop, get a cup of coffee, or anything else, you make them wait while you run NCUA and the examiner's name through your OFAC screen.

Yes - I am being snarky but I hate when common sense goes out the window.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#1969932 - 10/16/14 05:56 PM Re: OFAC screening on domestic banks Sisyphus
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,211
New York City
I tend to agree with PR. If you're manually screening for OFAC compliance, there is zero benefit to screening US domestic banks.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
#1969944 - 10/16/14 06:07 PM Re: OFAC screening on domestic banks Sisyphus
CULady Offline
Gold Star
Joined: Sep 2007
Posts: 495
WA
With anywhere from 3-10 wires a day, it's hardly cumbersome.

I get it though. But after being told one year it was fine as long as we put it in our policy that we accept the risk of not checking domestic banks and then the next year having them on our case about it, it just wasn't my time and effort to argue it.

And honestly if they weren't on our case about it, I probably wouldn't either! smile

Return to Top
#1969948 - 10/16/14 06:12 PM Re: OFAC screening on domestic banks Sisyphus
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,781
You are here
That is only for wires how about; new accounts, lending, accounts payable, ACH...
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#1969950 - 10/16/14 06:15 PM Re: OFAC screening on domestic banks Sisyphus
Sherlocked Offline
Member
Joined: Dec 2013
Posts: 82
221B Baker St.
What are the chances of a domestic bank being on the OFAC list? Do you think a domestic bank would still be open if on the OFAC list?

We don't OFAC domestic banks, have it in our policy and our examiners haven't said anything about it.
_________________________
"I’m not a psychopath. I’m a high-functioning sociopath. Do your research.” -Sherlock

Return to Top
#1969992 - 10/16/14 07:21 PM Re: OFAC screening on domestic banks Sherlocked
CULady Offline
Gold Star
Joined: Sep 2007
Posts: 495
WA
Originally Posted By: Sherlocked
What are the chances of a domestic bank being on the OFAC list? Do you think a domestic bank would still be open if on the OFAC list?


One would hope none... That was the same case I made with the NCUA. If there were doing bad things, pretty sure they wouldn't be sending wires to a small CU in OK...

Return to Top
#1970442 - 10/20/14 12:18 PM Re: OFAC screening on domestic banks ACBbank
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
Originally Posted By: ACBbank
I tend to agree with PR. If you're manually screening for OFAC compliance, there is zero benefit to screening US domestic banks.
Ditto. And we don't. And our risk assessment reflects that fact.

Return to Top

Moderator:  Andy_Z