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#2087054 - 07/07/16 06:27 PM OFAC on credit card authorized users
Calmeida12 Offline
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Posts: 249
Does anyone know if OFAC needs to be run for credit card authorized users? Thank you.

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BSA/AML/CIP/OFAC Forum
#2087059 - 07/07/16 07:05 PM Re: OFAC on credit card authorized users Calmeida12
John Burnett Offline
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John Burnett
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Cape Cod
OFAC doesn't require you to run anyone by its SDN List. It only cares that you not violate OFAC regulations. Your bank should do a risk-based analysis of authorized users of credit cards to figure out whether you want to scan such names against the list.
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John S. Burnett
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#2087064 - 07/07/16 07:25 PM Re: OFAC on credit card authorized users Calmeida12
Calmeida12 Offline
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Joined: Sep 2012
Posts: 249
Thank you John. My next question is: What about CIP, should the 4 basic CIP items be collected for credit card authorized users?

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#2087066 - 07/07/16 07:32 PM Re: OFAC on credit card authorized users Calmeida12
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The regulation would not require it, because as authorized signers these people are not customers. But if your CIP requires it, you have to abide by those in-house policies.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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