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#43404 - 11/15/02 06:40 PM OFAC and cashiers' checks & savings bonds
Anonymous
Unregistered

I need to confirm whether we are required to check the OFAC list for "payees" on cashier's checks as well as purchasers and designated recipients of savings bonds sold? savings bonds redeemed? How are other banks handling these? Thanks for any and all help.

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Operations Compliance
#43405 - 11/15/02 06:54 PM Re: OFAC and cashiers' checks & savings bonds
Kara S Offline
Platinum Poster
Joined: Oct 2002
Posts: 927
Milwaukee, WI
I would also like to know about Purchaser's of Traveler Checks.
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My opinions are not to be construed as legal advice.

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#43406 - 11/15/02 07:01 PM Re: OFAC and cashiers' checks & savings bonds
Michelle M Offline
Gold Star
Michelle M
Joined: Oct 2002
Posts: 422
I don't know, but it would make sense. I mean if a check is made out to Osama I think they'd want to know about it. OK that sinario would never happen, but you get the point.
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Michelle M Opinions do not necessarily reflect those of my employer nor are they legal advice

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#43407 - 11/15/02 09:05 PM Re: OFAC and cashiers' checks & savings bonds
Anonymous
Unregistered

The government wants us to check on anybody and everybody. Don't forget the Control list and the soon to be "other government lists" I don't think there is any way we can meet all of their expectations unless you have a wonderful support systam that has the OFAC list built in, otherwise we the financial industry can not verify every item processed in our place of business. Good luck.

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#43408 - 11/15/02 09:31 PM Re: OFAC and cashiers' checks & savings bonds
KSherrell Offline
100 Club
KSherrell
Joined: Nov 2002
Posts: 139
CA
I have my tellers check the payee's of cashierís checks, only if itís not an identifiable entity, i.e. no need to check Washington Mutual or Allstate.

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#43409 - 11/15/02 09:56 PM Re: OFAC and cashiers' checks & savings bonds
Joan Offline
New Poster
Joined: Nov 2002
Posts: 24
How do you document that the OFAC list was checked?

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#43410 - 11/19/02 04:20 PM Re: OFAC and cashiers' checks & savings bonds
CalifDreamin Offline
Diamond Poster
CalifDreamin
Joined: Mar 2002
Posts: 2,225
Far from Calif
I know some institutions that retain a log of OFAC searches. We are lucky here in that our IT Dept. actually implemented an in-house system where by we check it on our intranet and there is an audit report that is created showing what you checked, who checked it, date, time, etc. I can get you in touch with our IT Dept. if you want to discuss it further.
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#43411 - 11/20/02 03:37 PM Re: OFAC and cashiers' checks & savings bonds
Joan Offline
New Poster
Joined: Nov 2002
Posts: 24
Thanks for the input. I'll get back to you if we decide to "automate" the search confirms.

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#43412 - 11/20/02 09:24 PM Re: OFAC and cashiers' checks & savings bonds
Anonymous
Unregistered

We print the copy showing no matches, which our software aloows us to do. Yes, we have paper everywhere, but it's the only way we can prove that we verified it and that we used the correct updated file.

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#43413 - 11/20/02 09:50 PM Re: OFAC and cashiers' checks & savings bonds
Joan Offline
New Poster
Joined: Nov 2002
Posts: 24
Thanks for the suggestion- what happens when there's a hit on a payee name? say for example you have a good client who wants a cashier's check payable to fidel castro, and not THE fidel castro but someone your client needs to pay?
Can one of the GURUs comment...what are we to do?

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#43414 - 11/20/02 10:45 PM Re: OFAC and cashiers' checks & savings bonds
Lestie G Offline

Power Poster
Joined: May 2002
Posts: 3,606
Near the Land of Enchantment
We get 'hits' all the time. We're in a part of the country where a lot of common names are hispanic - as are most Cuban and Columbian names.

We simply research to ensure that this 'Juan Gonzales' is not the same as the Columbian drug lord on the list. We do that by determining where he lives, what his birthdate is, finding out if our bank staff have known him all their lives and gone to elementary school with him, etc.

If you can't determine that the person/entity isn't the one on the list - then you contact OFAC and do as they tell you.
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