It seems that OFAC compliance has gotten a lot more attention in the last couple of years, even in the rural heartland. I would be interested in knowing how others in smaller, community banks are handling the initial search and the annual monitoring issues. Any information regarding special procedures and/or software that monitors customers and transactions would be appreciated.

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Opinions expressed are not necessarily those of my employer.

CAnderson says "annual monitoring issues" - I'm wondering WHAT annual monitoring issues? Nothing I'm aware of in OFAC requires or even suggests annual monitoring requirements. OFAC is an ONGOING monitoring issue, and I'd be reluctant to suggest only annual monitoring for even the lowest risk profile insitutions.

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Jim Bedsole, CRCM, CBA, CFSA

Opinions expressed are my own, and do not necessarily reflect those of my employer.

I am referring to the part where the bank must "regularly" review all accounts to verify that an established account has not been placed on the OFAC list. Sorry for the confusion.

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Opinions expressed are not necessarily those of my employer.

We use the Bridger Systems OFAC Tracker software. We download our CIF database into the software and it runs through all of the names and address on the CIF against all of the info on the OFAC list. It produces a report on any hits, near-hits, etc. based on the tolerance level you set.

And yes, it's annoying when a customer who lives on a street named Tripoli Lane comes up because Tripoli is a regulated country. You also have to wade through customers with common Hispanic names because so many of those names are on the SDNT list.

I believe Thompson Financial has a similar product now although I do not have any experience with it.

You can find information about Bridger Systems at http://www.ofaccompliance.com They also have a free feature where you can type in a name and see if it matches any on the OFAC list.

Does anyone use their OFAC monitoring on loans? If the customer does not have a deposit account, what would be the procedure if there was "hit"? Thank you.

We run all loans through our software. If there was a match, we would contact the hotline and find out what to do next.

We also run all accounts through a master file check quarterly to make sure no accounts are missed.