When opening a new account, and the individual or business happens to be a hit on the OFAC list, are we then obligated to open the account or can we refuse?

At a seminar I attended back in the spring, we were told that a deposit side transaction should be completed.

A common thought was that the government wants these funds out of circulation. That is done by opening the account and then freezing the funds.

This may also be better for the CSR opening the account as the hostility level will be lower... until the next day. I would consider employee safety in any procedure you follow.

In reply to:

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I would consider employee safety in any procedure you follow.

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I agree, Andy, but has OFAC given any kind of opinion on this? (I am sure they would want us to consider that as well, at least I hope they would)

I have gotten verbal opinions from OFAC to that very effect. They don't have a problem with screening the account on the back end, as long as you have a process in place to identify the account as one that requires blocking by the next business day, especially where this keeps the bank employees out of potentially dangerous confrontational situations.