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#2039708 - 09/21/15 07:33 PM Potential OFAC IAT Match
Purex Offline
100 Club
Joined: Oct 2005
Posts: 181
South
Situation:
Potential 100% match off of name alone, alias that is, for an IAT transaction that attempted to post to our customer's account. I have notified OFAC, got a call within 20 minutes, gave all information available. OFAC states not enough information to confirm/deny it's a positive match, and that the Bank cannot use ACH Return Reason Code R16 based on OFAC did not clarify it was indeed a positive match. Now I am stuck note having any further information and no ACH reason code to return this transaction, I do not want to post it. I can tell it is one of these Ebay Paypal transactions based on the customer's spending history. Any advise?
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#2039799 - 09/22/15 01:20 PM Re: Potential OFAC IAT Match Purex
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
I would look at who my customer is, how long they have been in the area, what they do, what their online activity is, etc., against which group in OFAC your match is in and determine if it makes sense that your customer could be on OFAC.
We get these matches quite often now and always for small amounts and use the above process.

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#2040162 - 09/23/15 06:24 PM Re: Potential OFAC IAT Match MagicCity
Purex Offline
100 Club
Joined: Oct 2005
Posts: 181
South
Our customer's history indicates that they are a heavy E-bay/Paypal user. I often purchase from E-Bay myself. This customer is not the potential OFAC match, but rather the person from which our customer has made a purchase from an international country. It is so hard to make a determination based on the little criteria that we have. Our customer's activity in their account is not unusual.
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#2040340 - 09/24/15 04:07 PM Re: Potential OFAC IAT Match Purex
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
I think if the transactions do not appear unusual and the amounts are not out of the ordinary, I would consider it a false positive, as all information does not match.

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