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#524543 - 03/30/06 03:30 PM OFAC screening requirements
Compliance101 Offline
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Compliance101
Joined: Oct 2004
Posts: 473
Tennessee
I have recently started a new job (within the past 2 weeks) as a compliance assistant. I have been out of compliance (working in a bank) for 8 months, so somethings have left my memory. I am currently trying to update the OFAC policy and cannot remember what all has to be scrrened through OFAC. Do monetary instrument sales have to be screened, safe deposit boxes? Could anyone tell me where to go to get the requirements? Thanks a lot!!
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BSA/AML/CIP/OFAC Forum
#524544 - 04/04/06 04:33 PM Re: OFAC screening requirements
Sunshine_101 Offline
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Sunshine_101
Joined: May 2005
Posts: 127
http://www.treas.gov/offices/enforcement/ofac/faq/index.shtml

This might be a good place to start for a refresher.
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#524545 - 04/04/06 04:44 PM Re: OFAC screening requirements
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
You will not find any lists of things your are required to check. Complete the poll and you will see what others are doing.
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#524546 - 04/05/06 04:53 PM Re: OFAC screening requirements
First Banker Offline
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First Banker
Joined: Apr 2005
Posts: 403
Florida
I just looked at the poll numbers again, and was shocked to see the high percentage that check nothing on ACH. Am I wrong in thinking that it is required?

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#524547 - 04/06/06 03:07 PM Re: OFAC screening requirements
Carolina Blue Offline
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Carolina Blue
Joined: Jul 2005
Posts: 961
Lost in a regulatory fog
See every other response to OFAC questions, "nothing is required, but...."

I think as long as you only allow domestic ACH you should be okay not checking. We are all relying on each other to check our own customers against the OFAC lists. Here's a link to NACHA's OFAC Guide NACHA OFAC Guidance

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