We issue monetary instruments to our customers. Our core, FIS checks non-customer payees against OFAC. I am writing procedures for the frontline staff of what to do if there is a "hit." Understandably, 99.99% of the time, it will be a false positive, and a supervisor can review to authorize the transaction. However, if it appears to be a true match, the staff will have to contact the BSA Officer (me) for further investigation. My concern is that we have branches that are open early / late / Saturdays. What is the best procedure if there is a match and the BSA Officer is not available?

Should the burden be on the frontline staff to make the decision and tell a customer no (risking customer service) until the BSA Officer does a review at a later date?

Or should the check be issued, and the BSA Officer notified of the transaction in order to complete an investigation the next business day? And if it is determined at that time to be true OFAC match, can a stop payment be placed on the instrument per § 3-411. REFUSAL TO PAY CASHIER'S CHECKS, TELLER'S CHECKS, AND CERTIFIED CHECKS. (c) Expenses or consequential damages under subsection (b) are not recoverable if the refusal of the obligated bank to pay occurs because (iv) payment is prohibited by law..?

We train certain staff (branch managers, head teller, department managers, etc.) to be able to view our possible matches when Compliance is not available. This enables the "hit" to be verified prior to purchase.

We have our front line people review the hits and document the false positive. Only if it is truly a hit they would contact us in the Compliance department.