We have recently had an audit finding because we are not running OFAC on non-customers cashing checks. In the past we have decided to accept the risk on this, and will likely continue with that approach, however, I have been asked for the practice of my peers before we finalize that decision. This being said, is anyone willing to share their practice in regards to OFAC and non-customer check cashing...I'd greatly appreciate it.
Thank you!

We also do not OFAC non-customer cashing check and have accepted the risk and added it to our BSA/AML policy. We have never been criticized for our procedures.

We DO check non-customers prior to check cashing (Jack Henry & Associates processor). The tellers can usually do a quick OFAC check in accordance with our procedures very quickly.

We only check OFAC on non-customers over a certain $$ amount. It is a risk decision that must be tailored to your institution.

Same here.

We also check OFAC for non-customer check payees at the teller line.
We were written-up for not having this procedure in place by our examiners last year.

We were written-up for not having this procedure in place by our examiners last year.

It was in your report of examination? Really? Didn't you already cover this in your OFAC risk assessment? They criticized that too then I suppose?

Checking non customers, but only over a certain dollar amount is a tad cynical, but it works as a sop for some examiners. (Risk isn't strictly limited by the amount of the check, but checking over the counter payees is a ridiculous passtime either way.)

rlcarey- yes, we were told to add it to our OFAC risk assessment.

Being told something by an examiner and written-up is too very different things. It would never make it to the report, as there is no basis of a regulatory violation for them to cite. It was just one examiner's opinion at this point. Addressing it in your risk assessment is another issue. I would and say the risk is so low, we deem it not necessary to check.

My apologizing for being vague when I said "we were told". It was included in the final report.

lol, long day. I meant "apologies"

Then I would have been calling my ombudsman because something that does not rise to the level of a violation of law should not be in a written report.

rlcarey is correct, but I dealt with a bank last week where it was in their written report and it focused on their insurance subsidiary. They were directed to run OFAC checks on the policy holder and the beneficiary on an ongoing basis. (That's an indicia of pure ignorance.)

OFAC compliance is risk based; it simply isn't up to the regulator to give directions on this point. Their role is limited to pointing out the deficiency in the risk assessment. However, if the bank is not willing to contest the finding...

We just had auditors here and they spent the good part of two weeks just reviewing OFAC and the last exam they also really heavily looked at ALL aspects of OFAC so I am guessing that OFAC is a hot button or hotter button these days LOL . To answer the original question yes WE DO OFAC non customers for OFAC for a specific threshold at the line.

"We just had auditors here and they spent the good part of two weeks just reviewing OFAC."

If these are external auditors hired by your bank or internal auditors, they are wasting your money. Someone needs to have a talk with them unless for some reason you are a very high risk OFAC institution.