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#2195794 - 10/18/18 01:32 PM OFAC Hit?
SmallBankBSA Offline
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Joined: May 2018
Posts: 158
I have a potential OFAC hit for an SDN and I am unsure how to go about determining if it is a true hit as I have limited information.... customer originated a low dollar (less than $10) international ACH and the hit is on the name of the individual on the SDN list. I have no other information on the international ACH other than the name and the country which are matches to the alias on the SDN list.
I've left a message with OFAC and am waiting for a call back. The transaction was rejected by our core processor and I know I have ten days to report this to OFAC, but I can't be certain it is a valid hit. Additionally, the foreign name appears to be common in that area.
Any advice for someone who never got a potential true hit?
Thank you.

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#2195800 - 10/18/18 02:18 PM Re: OFAC Hit? SmallBankBSA
HappyGilmore Offline
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Pulling people out of the ditc...
ask your originator to provide additional information on the payee that may help you determine if a true match
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#2195802 - 10/18/18 02:20 PM Re: OFAC Hit? SmallBankBSA
SmallBankBSA Offline
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Joined: May 2018
Posts: 158
Thank you. I will ask the branch to contact the customer.........do you have advice on how to phrase the question to the customer to gather the additional information? I'm sure I'll get push back as to why the bank is requesting information on what a person is purchasing.

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#2195804 - 10/18/18 02:25 PM Re: OFAC Hit? SmallBankBSA
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,272
Illinois
The OFAC list is publicly available. Your customer would be subject to the same OFAC sanction penalties as the bank if they conduct a transaction with sanctioned person. You tell the customer that you want to determine if we can conduct business with the other party to the transaction.
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#2195807 - 10/18/18 02:40 PM Re: OFAC Hit? SmallBankBSA
SmallBankBSA Offline
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Joined: May 2018
Posts: 158
Thank you

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#2195833 - 10/18/18 04:21 PM Re: OFAC Hit? SmallBankBSA
MNCompliance Offline
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Joined: May 2018
Posts: 14
I had something similar and called OFAC (left a message and they called back within a couple hours). Ask if it was a paypal transaction and a lower dollar amount. The guys said that the name was very common for that region. He said it was most likely a false positive but that it was ultimately the banks decision based on our risk.

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#2195855 - 10/18/18 05:57 PM Re: OFAC Hit? MNCompliance
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,477
Pulling people out of the ditc...
Originally Posted By MNCompliance
I had something similar and called OFAC (left a message and they called back within a couple hours). Ask if it was a paypal transaction and a lower dollar amount. The guys said that the name was very common for that region. He said it was most likely a false positive but that it was ultimately the banks decision based on our risk.


yes, OFAC is very helpful like that...
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#2195867 - 10/18/18 06:41 PM Re: OFAC Hit? SmallBankBSA
thomasj Offline
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Joined: Mar 2001
Posts: 5,063
Pennsylvania
There seem to be a lot of IAT OFAC hits related to Paypal transactions. It would be nice to know the extent of Paypal's OFAC compliance policies. Also, if you had a hit on a Paypal transaction how much luck do you think you would have calling Paypal to gather additional identifying information on the person that your customer is sending $2.99 to?
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#2195887 - 10/18/18 08:09 PM Re: OFAC Hit? SmallBankBSA
SmallBankBSA Offline
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Joined: May 2018
Posts: 158
Thanks everyone. I finally heard back from the Treasury Dept and the representative knew exactly what I was talking about (the name, the area etc) and said it was up to the bank if we wanted to accept the risk

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#2195907 - 10/18/18 09:12 PM Re: OFAC Hit? SmallBankBSA
RockChucker, CAMS Offline
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Joined: Jul 2013
Posts: 1,644
The Country
Originally Posted By SmallBankBSA
Thanks everyone. I finally heard back from the Treasury Dept and the representative knew exactly what I was talking about (the name, the area etc) and said it was up to the bank if we wanted to accept the risk


In other words they were of no help whatsoever!
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#2196031 - 10/20/18 12:12 AM Re: OFAC Hit? SmallBankBSA
TryingtoComply Offline
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Joined: Apr 2013
Posts: 1,921
The West
There are so many common names on the OFAC list. Without additional information you really can't do much. Their comment about accepting the risk is likely due to the dollar amount. For less than $10 I would accept the risk.
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