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#2254473 - 05/27/21 12:39 PM Incoming IAT Debits and OFAC
heatherdem Offline
New Poster
Joined: Dec 2019
Posts: 3
How are FI's handling incoming IAT debits when you are unable to complete OFAC screening by EOD? The OFAC Letter issuing revised guidance, dated 3/18/2009, says that the suspect transaction can be removed from the batch for further investigation, but what do you actually do with it? 99.9% of the time we are simply waiting for clearing data from our clients, but sometimes they are not timely.

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BSA/AML/CIP/OFAC Forum
#2254494 - 05/27/21 03:24 PM Re: Incoming IAT Debits and OFAC heatherdem
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,312
Illinois
You have two choices. Either accept the risk and post the transaction or reject it. Personally, given the potential fines involved with OFAC, I'm not a big proponent of accepting the risk for a $9.99 PayPal transaction.
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#2254500 - 05/27/21 03:59 PM Re: Incoming IAT Debits and OFAC heatherdem
heatherdem Offline
New Poster
Joined: Dec 2019
Posts: 3
Thank you!

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#2254619 - 05/28/21 03:32 PM Re: Incoming IAT Debits and OFAC heatherdem
Jennifer Offline
100 Club
Jennifer
Joined: Dec 2014
Posts: 177
If our bank cannot clear it that day, we reject it based on risk.

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