When a new account is opened, we run the person thru Chex Systems, to find anyone whose account we must freeze. If the customer comes back next week or in several months, do we need to run the check again? We keep records to show we ran the initial check.

Because the lists (OFAC/Control) change, you'll need to run the customer's names thru a database check quarterly or on some other policy approved schedule. Established customers don't need to be checked each time they do something.

We also use Chexsystem at opening and then do a full client list check annually.

I recommend doing a full check of your customer base each time the OFAC list changes (but especially when names are added to the OFAC list). Otherwise, you might have a customer that opened an account 6 months ago and everything was fine, but today you might be required to freeze their account and report it to OFAC. If you're only checking annually, you could be at significant risk.

I agree. We are concerned that someone with an existing account will show up on the list. We use ChexSystems @ acct. opening and run the OFAC the day we receive it.

Have all of your banks purchased software to scan your database? Any suggestions for a small $100 million bank? We really watch our pennies, so we are looking for the most cost effective method available.

Some systems are less expensive than others and still of acceptable quality. Shop around. We also have deep pockets and short arms. We went with Bridger. An automated system is 99% a must because it is cost effective.

We also use Bridger and have found it to be both easy and economical.

We just recently purchased Attus WatchDog, and we've been very pleased with it so far. It was very reasonably priced, simple to use, fast, and produces good reports. They worked with our core processor to build the file definition for checking our entire database, so we didn't have to mess with that.