My department was asked by HR to see if a process can be simplified. Our policy states that, at new-hire and on 2 year basis, each employee needs to be checked against 5 "banned from banking" databases (FDIC, OCC, FRB, SEC, NCUA) . With 300+ employees, this is quite a manual chore...

Curious - does your bank do anything like this? Is it a manual process, or is there any services out there to accomplish this?

Interesting, why would you think you would need to re-run existing employees through the ringer?

if they weren't on the list when you hired them, the only way they could get on the list while working for you is going to be well known by your bank, because it is likely coming with some type of sanction from teh regulatory bodies you've mentioned.

I haven't experienced that level of checks but I can see where it could be handy because many times an individual that does something that can get them banned from banking it can take years to move through the system.

Many watchlist screening tools allow you to upload a custom list. You may already have this capability in the bank for OFAC compliance, you would just need to format the info from the database into whatever your vender needs.

I personally think it's excessive. I don't exactly know - I believe this came as an examiner recommendation. Or someone misinterpreted an examiner recommendation - and now an excessive procedure was put in policy.

Randy, what would you think would be sufficient? Manually run them against the 5 databases at time of hire, and call it good?

We implemented this process at the time of hiring at the request of our regulators and we conduct the screening with OFAC and other HR screens.

I do understand the logic of running it sometime after hiring though. The process of barring someone from banking is a very slow process and it may not become public knowledge for years after the fact.

I can understand the logic, but I would think there is a better way to manage this. Regularly searching 5 separate databases is a bit cumbersome.

It should be automated process. If you are using a name screen model for sanctions/adverse media screening, it should just be added another a list to the existing portfolio. I would suggest calling your vendor and asking them about what options are available.

if you have an employee that is banned, you will know because your regulator will tell you at the point they are banned- even if they are being banned for something they did at another bank.

while the process can be slow to ban them, during that slow process they will not show on any list, because they have not been banned.

And if someone is banned while currently employed by another financial institution and they do not tell them, they are looking at jail time.