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#2246499 - 12/14/20 05:22 PM Originator - incoming wire
nu2regs Offline
Member
Joined: Mar 2013
Posts: 77
We had an incoming wire where the origination section as:
Business name
C/O another business name
Address

Who would considered the final originator of the transaction? 1st business or the business that is C/O

Thanks for assist.

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General Discussion
#2246500 - 12/14/20 05:25 PM Re: Originator - incoming wire nu2regs
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,694
Illinois
The only way you will get an answer to this question is to contact the originating bank. Regardless of the answer, I'd perform an OFAC search on both names prior to posting the transaction.
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#2248110 - 01/25/21 07:22 PM Re: Originator - incoming wire nu2regs
Cbigun Offline
100 Club
Joined: May 2016
Posts: 167
Are you saying that before accepting a wire in for a customer, the originator of that wire must be checked against OFAC? Doesn't the originating bank have that responsibility or whoever you process through?

Wire in for John Smith from Talent Title Company

Talent Title Company = OFAC??

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#2248117 - 01/25/21 07:35 PM Re: Originator - incoming wire nu2regs
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,694
Illinois
Are you willing to accept the compliance and financial risk that the originating bank performed the search? I'm not.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

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#2248156 - 01/26/21 03:14 PM Re: Originator - incoming wire nu2regs
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
Most wire processing systems will screen all parties today. Regarding OFAC screening - the risk is really up to you. It's simply not worth the risk of a sanctions violation. Most FI's I know screen all parties on wires.
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