We are having a discussion. Can somebody clear this up for us? Is a bank required to have a printed version of the OFAC list on its premises?

I hope not...we don't. Our processor runs OFAC against the database.

We do. It is there as a fallback in case of a DRP type scenario. The OTS likes that we have it, so I plan to keep it.

We do not. Our processor runs OFAC against database on a weekly basis. You can also go online to verify a new customer.

The OFAC regulations do not require anything - really - other than an absolute prohibition to allow transactions involving blocked parties. How you do that is supposed to be up to your institution, but if you fail to block a transaction, you could be in big trouble if it's determined that your policies and procedures were inadequate.

Having said that, I'm not sure how a hard copy of the ever changing-many paged-small font list would be add any adequacy to anyone's policy or procedure.

Bonnie's right. There's no requirement to have a printed list or anything really. However, you need to have a way to review the list. However, the printed list would be very inefficient and it's out of date the day it is printed.