Yes, but have you screened the originator of the incoming wires? They are not your customer. I know I am being the devils advocate on this, but we all are assuming that the bank originating the incoming wire has verified the information on their end before initiating the wire. But what if they didn't? That leaves you liable if the originator is on OFAC. It's a matter of determining what amount of risk we want to take and if it is worth the man-hours to verifiy this information. I for one think it is. In a time of heightened awareness of this issue, I don't see how we could not take that extra step. We too have verified (and verified and verified) our customers, it's the other end of the transaction that I am worried about. Another scary thought is that we too are learning and adjusting our program as this whole thing progresses, but I also just found out that some of the employees were only checking OFAC if the name appeared unusual (foreign).!!!
So when I prepared my monthly newsletter I pulled out that old manual from OFAC (before the electronic systems) and pulled about 20 common names that you would not suspect would be on the OFACs list. I was hoping this would instill in them that it is not just foreign sounding names/companies that we should be checking.