Can anyone please tell me what they do regarding their procedures for checking OFAC sources when wire transfers are received by our customer from the same sender once a week. Does the sender have to be check against the OFAC list every time or can it be done periodically. The same question applys for an outgoing wire transfer situation (same customer sending to the same benificiary once a week).

Thank you.

Well, we just got a notice that the SDN list was updated today, so you may want to check more than just the once...

I'd at least check every time the list is updated, if you can get notification when that happens.

I think you would get criticized by examiners if you did not do it each and every time as OFAC updates so often.
I tried that argument with both auditors and examiners on extremely well known local attorneys and title companies that send and receive wires daily. We all know that they (the local attys and title companies) are not on OFAC and yet every day we have to check OFAC and print out the results and attach it to the wire.
And they both stated we have to do it each time.
It's a real waste of time.

I think if you maintain a recurring wire list, and you check the names on it each time OFAC changes, you'd be ok.

I'm reviving this thread because I would appreciate learning how and when you are checking your outgoing wires? Our volume is getting too heavy to manually check them, so we are trying to find a better solution. Any suggestions would be greatly appreciated!

We use product from Thomson Financial called Facline. It is a software program that scans each wire from a disk or our network. Another company is Lyons Data (maybe Lyons Finacial Data) and they have a similar product as well. It takes about 10 seconds to scan 100 wires, so it is a minimal amount of time per day to our wire area. It also creates a log that is archived to our network that we can access to show auditors we are checking. We use this for both incoming and outgoing wires per day. A google search on OFAC SCANNING will give you a number (133,000) of options.

We have the FACline program also. I guess we are not using it to its full potential. Thanks for the input.

We use OFAC Watchdog for our clients.