Is anyone doing an OFAC search on NEW JOB APPLICANTS or doing a search AFTER HIRE?

JanDan:

Although it's not yet a common practice, many institutions are conducting background investigations on every insider and third-party service provider that may have access to consumer data -- as part of their Information Security Programs. This background check should include OFAC checking.

We have built that into our procedures. It's yet another way of covering yourself!

Our Personnel Dept., Manager insists on NOT doing an OFAC search on new hires......I think we should

Do you open accounts for new hires? If so, 326 is not going to give you a choice on checking OFAC.
That being said, I am very curious as to what otherworldly logic your Personnel Manager is using.

It's hard to believe after the BONY debaucle that anyone would question an OFAC search on ALL employees! Since 1999, Know Your Customer has always meant Know Your Employee as well.

Our Personnel Dept., Mgr also insists on not performing an OFAC search because it's "not job related" and the OFAC list gives names of "SUSPECT" money launderers & terriorts...we do perform a criminal investigation on all new hires, regardless of position....