We use eFunds Penley for ID Verification and OFAC checks. My question is, are we supposed to do an ID Verification & OFAC check EACH TIME a beneficial ownership form is completed for each beneficial owner, the control person, AND the business? What if they have had the searches done on them in the past?

This is my understanding:

1. OFAC checks are up to your bank's own risk assessment and risk tolerance.

2. ID: Identify AND verify. If you have the owner's ID on file, great, you know your owner. If not, collect or make a copy of their IDs. That's my understanding and interpretation.