Id like to see how many banks are checking bank check payees (whether you sell to customers and/or to non-customers) against the OFAC list. Thanks in advance for your responses.

pizzaz, what was the resulf of your poll?

Based on the above information (the poll results) and banks within my state, most are not checking check payees against the OFAC list.

Those of you who are checking the payee, what are you doing when you get a suspect hit (i.e. from a customer relations perspective). My concern is not having enough information on the payee to determine if it is a true hit and refusing the sale to our customer. Payee name only - no other info available...dob, address, when comparing to the OFAC list

I think the 8 that said they do are lying. Unless they have minimal volume, there is no way that anyone is looking at every check coming in to their bank to scan the payee for OFAC...

I thought I was one of the 8. Maybe I did not understant the question correctly. We do not scan all incoming items. We do the payees of official checks at the teller window at the time of sale if they exceed a certain amount. It's a risk based decison.

PG,

What do you do if you have a suspect hit?

PG,

If you do get a match at the teller window, how do you know it's a real match not a false positive? Do you ask the customer for the payee's address? Or simply refuse the sell the cashier's check? Wouldn't a match (and false positives) cause a panic in the lobby?

I'm just curious...

We check all negotiable instruments of non-customers against OFAC- payee and payor because we are the only bank in two very small towns and we have a lot of non-customer transactions from purchasing certified checks and money orders to cashing local payroll checks. Our auditors agreed with the practice since anyone, anywhere can show up on the dreaded OFAC list. Additionally it would seem that a little town and a small bank combination might be the perfect forum for the bad guys. We might be over the top-but better safe than CMP's! And I agree- it's a risk based thing.

For what it's worth, we do not check payees at the time of the sale. We do, however, include official checks in our quarterly OFAC scrubs. I'm not sure what we would do if we actually got a hit since the sale could have occured as much as three months ago.

Have you had any name matches yet? I can foresee the likelyhood of a false positive hispanic name match. Do you refuse the sale? Require further identification of the payee to document that it's not a hit? Other?