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#2166015 - 02/27/18 05:32 PM Non-customer log
Banker57 Offline
Gold Star
Joined: Jul 2010
Posts: 439
Minnesota
Back in the day we required a manual log of all non-customer transactions. This was used to verify that the manual OFAC check was being done. We are now using an automated OFAC module that will prompt for the OFAC verificstion and not allow the transaction to continue unless the OFAC step is completed. A report will then be generated of all the OFAC verifications done. My question is are we still required to keep a manual log of non-customer transactions?

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#2166019 - 02/27/18 05:41 PM Re: Non-customer log Banker57
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,450
Somewhere
We do not have a log, nor have we ever to my knowledge and that sounds like a very outdated practice. If you allow non-customer trans., just comply with the regulations and maintain records as detailed in your record retention policy.

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#2166119 - 02/28/18 12:34 PM Re: Non-customer log Banker57
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
There is no requirement for a log. Yet, your new software provides you with one. There is certainly no need to have two.
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