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#2095488 - 08/26/16 03:25 PM OFAC Reporting requirements for Narco Trafficking
jhoch Offline
Member
Joined: Nov 2014
Posts: 66
Are there different reporting requirements if a true OFAC/Sanctions match is related to narcotics trafficking or terrorist financing? I have someone telling me that it has to be reported immediately via phone or e-hotline. I don't see any guidance stating that these matches are reported differently than any other true OFAC/Sanctions match.

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BSA/AML/CIP/OFAC Forum
#2095644 - 08/26/16 09:28 PM Re: OFAC Reporting requirements for Narco Trafficking jhoch
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
You need to report a blocked or prohibited transaction to OFAC within ten business days.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2095648 - 08/26/16 09:58 PM Re: OFAC Reporting requirements for Narco Trafficking jhoch
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
To save yourself some valuable time in the future, if someone else says "it has to be xy or z". You ask them to show you where it says that. Saves you from going on a wild goose chase.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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#2095748 - 08/29/16 03:56 PM Re: OFAC Reporting requirements for Narco Trafficking jhoch
WIBanker91 Offline
100 Club
Joined: Nov 2011
Posts: 185
WI
What if you have a name match but are unable to confirm the DOB that is listed because the match is part of an ACH file and the submitter will not verify the DOB for confidentiality reasons?

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#2096098 - 08/30/16 06:08 PM Re: OFAC Reporting requirements for Narco Trafficking jhoch
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
I would contact FinCEN and ask for guidance
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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#2096992 - 09/06/16 04:18 PM Re: OFAC Reporting requirements for Narco Trafficking jhoch
CFR31 Ch x Offline
Junior Member
Joined: Dec 2014
Posts: 31
FinCEN's phone number can be found here: https://www.fincen.gov/contactus.html or dial 1-800-767-2825 (option 1 for TF). They will have you explain the activity so they can summarize it to the FBI POC at FinCEN and also have you fax it (the SAR if there is one) over so the bureau can have it. The system updates nightly so they can't see your SAR until after the update is pushed which is why they request a copy.

Don't call FinCEN about your OFAC matters.
Last edited by CFR31 Ch x; 09/06/16 04:19 PM.
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