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#351749 - 04/26/05 07:00 PM Checking OFAC List
HR Banker Offline
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I'm interested to know how tellers check for hits on the SDN list when they sell a Cashier's Check or a wire transfer is made. Since the list changes so often I would think printing the paper version would be out. We have a place on our system to enter the information but you have to also have the address before it will check and that information is not always known by the customer in the office.

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#351750 - 04/26/05 07:15 PM Re: Checking OFAC List
BankerKB Offline
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We use bridgeinsight which allows you to search just by name or also to enter an address and more information.
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#351751 - 04/26/05 07:29 PM Re: Checking OFAC List
blvsinangels Offline
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The Bankers Bank also has a program that you can just enter a name, so does Check Systems.

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#351752 - 04/27/05 10:11 AM Re: Checking OFAC List
RVFlyboy Offline
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You can also direct your tellers to www.ofaccompliance.com. This is the website for ChoicePoint Bridger Insight. On the right hand margin, there is a link for Free Name Check. It does require a one time registration, but there is no fee. The registration does authorize ChoicePoint to periodically send you e-mail sales literature.
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#351753 - 04/27/05 12:41 PM Re: Checking OFAC List
waldensouth Offline
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MagicBanker, I have been told by sales reps at Bridger that the free on-line OFAC checker is not kept up to date and that we would not be in compliance if we used it. I understand that they were trying to sell me the full system and didn't want me to rely on the free one - but we stopped using that freebie altogether because of that statement by 2 different sales reps. This site is also free. Since it is the NASD site, I would think it is up-to-date.
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#351754 - 04/27/05 12:56 PM Re: Checking OFAC List
Anonymous
Unregistered

Quote:

... This site is also free. Since it is the NASD site, I would think it is up-to-date.




Well, one way to test how up-to-date it is would be by entering a new name from yesterday's update to the list.

Surprise! it is current......Very nice...

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#351755 - 04/27/05 03:01 PM Re: Checking OFAC List
Queen Mum Offline
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Queen Mum
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OK
We use Penley for both the 314(a), OFAC and ID Verification. Works well.

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#351756 - 04/27/05 04:12 PM Re: Checking OFAC List
RVFlyboy Offline
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Soaring over Georgia
Thanks for that, waldensouth. I had not heard that about the ofaccompliance.com site. That's a shame as they were one of the first out there. Too many mergers, I guess. Glad to know that NASD is picking up the slack. Gee, I wonder what it would take for OFAC to put that kind of technology on its own website.
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#351757 - 09/23/05 09:02 PM Re: Penley?
QCL Offline
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QCL
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NW IL
Quote:

We use Penley for both the 314(a), OFAC and ID Verification. Works well.




We're checking out Penley, does anyone else use their ID Verification service?

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#351758 - 09/24/05 09:33 PM Re: Penley?
Andy_Z Offline
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A lot of folks are using them. Be sure to let them know you saw them on BOL. They are a long time advertiser. Letting them know you saw them here goes a long way.
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#351759 - 09/29/05 01:25 PM Re: Penley ID Verification
QCL Offline
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QCL
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NW IL
Thanks Andy.

I need some advice for those of you that use it. We are going to, for the time being, use it as a tool in addition to obtaining a copy of the ID. How have those of you that use the Penley ID Verification explain to your staff that this doesn't take the place of your ID procedures?
I'm finishing up a power point for a training on it tonight and would appreciate any additional helpful ideas from those of you that have used it (or are using it).

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#351760 - 09/29/05 03:08 PM Re: Penley ID Verification
Ted Dreyer Offline
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Why don't you just say that your CIP policy requires both documentary and nondocumentary verification? It is your policy that controls at your institution.

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#351761 - 09/29/05 04:39 PM Re: Checking OFAC List
Maya Offline
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Joined: Jan 2005
Posts: 154
South Carolina
We recently started using a BankersSystem product. The question I have is how is everyone handling an OFAC hit on the payee of an offical check. Do you call OFAC while the purchaser is still in the bank or do you deny the transaction? Do you complete the transaction and then call OFAC?

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#351762 - 09/29/05 07:55 PM Re: Checking OFAC List
Ted Dreyer Offline
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#351763 - 09/29/05 11:05 PM Re: Checking OFAC List
dare2dream Offline
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Joined: May 2005
Posts: 128
California
is everyone checking the names on cashier's checks or is this risk mitigated? I keep hearing different things on if this is really required or not. We currently aren't checking cashier's checks/money orders and the such.
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#351764 - 09/30/05 01:58 PM Re: Checking OFAC List
BankerKB Offline
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Posts: 288
We aren't checking names on cashiers checks due to our risk level being low...it depends how you risk rate and develop your program
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#351765 - 09/30/05 02:28 PM Re: Checking OFAC List
Elwood P. Dowd Offline
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Next to Harvey
From the OFAC Q & A:

Does my bank need to check the OFAC list when selling cashier's checks and money orders? In the case of cashier's checks, do I need to check both the purchaser and the payee? As a mortgage lender, do I need to check both the purchaser and the seller's name against the SDN list?

Every transaction that a U.S. financial institution engages in is subject to OFAC regulations. If a bank knows or has reason to know that a target is party to a transaction, the bank's processing of the transaction would be unlawful. [09-10-02]


At the Dallas outreach program I asked the OFAC representative if a bank with a justifiably low risk rating for OFAC violations could reaonably omit some of the more mundane comparisons such as checking payees on on-us checks and payees on cashiers checks. It's fair to say she was appalled at the suggestion and answered with a rambling, but emphatic, "No."

See EGB's post "Regulatory Panel Notes" for confirmation as to what was said.

What examiners tell bankers varies incredibly among different parts of the country... OFAC's answers are always, "Yes, you have to check that."
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