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#370595 - 06/07/05 10:31 PM automated deposit service for union members
Anonymous
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Members of a union receive vacation pay as part of their union contract. We accept a deposit of the vacation pay earned by the union member into a non-interest bearing account under the union member's name and ss# as reported by the administrator of the union's payroll.
All we ever receive is the name and ss#. No other information.
We are a credit union and these are not members, they are coded as non-members. The only service they are entitled to is withdrawal of the entire balance, no partical withdrawals are permitted.
I have several of these individuals whose names are matching OFAC hits when I ran my monthly system match.
The ofac hits only have names, no other identifying informaton and on my side I just have name and ss#.
How do I proceed and find out if my match is positive?

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#370596 - 06/08/05 05:36 AM Re: automated deposit service for union members
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Call OFAC and ask if any of the matching persons has a US Social Security number.

You can also ask the union to provide you with DOB and address info and see if any of that information is or is not a match on the OFAC list.

Review the FAQ's that OFAC has regarding how to determine if a match is positive or false.
http://www.treas.gov/offices/enforcement/ofac/faq/

I am guessing that you are getting hits on names such as Carlos Gonzales, Ceaser Rodgriguez, etc. I was at a bank where we had 5 DIFFERENT Carlos Gonzales's. Fun stuff.
_________________________
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Regulations are a poor substitute for ethics.
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