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#609434 - 09/05/06 08:13 PM OFAC Poll - Non Customer Inquiry
BOT1 Offline
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Joined: Oct 2002
Posts: 23
Florida
I'm sure this has probably been addressed, however I could not find any info in my BOL search. Can the readers let me know your policy/procedures relative to OFAC checks on non-customers cashing onus checks. Put simply, if a non-customer cashes a check at the teller line drawn on your institution does your FI conduct an OFAC inquiry? If so how is it documented? I appreciate any and all feedback.

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#609435 - 09/05/06 08:27 PM Re: OFAC Poll - Non Customer Inquiry
nk78 Offline
Member
Joined: Aug 2006
Posts: 67
Illinois
At the institution I previously worked at we had the tellers/bankers use the free name check service available on Bridger Insight to conduct OFAC checks on non-customers.

http://bridgerinsight.choicepoint.com/free-services.htm

The results would be printed out and filed in the daily teller work. Any matches of 75 or more would be reviewed further before completing the transaction.

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#609436 - 09/05/06 08:48 PM Re: OFAC Poll - Non Customer Inquiry
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,439
Somewhere
For checks exceeding $500, we do an OFAC check on the non-customer check casher. A checkmark and OFAC are written on the item.

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#609437 - 09/05/06 08:49 PM Re: OFAC Poll - Non Customer Inquiry
MadisonCali Offline
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Joined: Jun 2006
Posts: 2,515
It's in our bank policy to check non customers cashing checks.
The only documentation we have is the summary that prints next day for any partial/total matches. If they have what they think is a total match at the teller window, they request the assistant of the compliance officer, BSA officer, teller coordinator, and/or retail banking manager.
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#609438 - 09/05/06 09:53 PM Re: OFAC Poll - Non Customer Inquiry
First Banker Offline
Gold Star
First Banker
Joined: Apr 2005
Posts: 403
Florida
We OFAC the payee of any check $1000 or more that is cashed by a non-customer. The teller writes "ofac" with their initials in the upper left corner of the check.

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#609439 - 09/06/06 01:50 PM Re: OFAC Poll - Non Customer Inquiry
Dazed and Confused Offline
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Dazed and Confused
Joined: Feb 2006
Posts: 250
Big XII South
Most state and national banks that I see are using a dollar threshold as described above by several posters. But that's only if the non-customer wants to cash an on-us check -- as indicated by your poll question, JD. Most of these same banks do not cash checks that are drawn on other banks for non-customers.

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#609440 - 09/06/06 02:08 PM Re: OFAC Poll - Non Customer Inquiry
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
If you take this poll based on what you currently do, you will have the insight offered by a couple hundred BOL participants.
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#609441 - 09/06/06 02:53 PM Re: OFAC Poll - Non Customer Inquiry
stormie Offline
100 Club
Joined: Nov 2004
Posts: 102
Our Bank was not previously verifying OFAC on non-customers. However, external compliance firm made recommendation during their review. We are now verifying OFAC on cashed checks for non-customers.

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#609442 - 09/06/06 06:02 PM Re: OFAC Poll - Non Customer Inquiry
Redsst Offline
Member
Joined: Apr 2006
Posts: 71
Our tellers use the OFAC inquery built into JackHenry for all non-customer cashing checks. The tellers also have a stamp that they put on the back of the check that has a place for ID type, ID#, expiration date, and the word OFAC that the teller initials by if no matches are found.

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#609443 - 09/08/06 09:19 PM Re: OFAC Poll - Non Customer Inquiry
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
In reply to the posting that references Bridger / CHoicepoint free services link. DO NOT USE THIS LINK. I was interested in purchasing other services from them and asked about it and they verified that they DO NOT update the OFAC list that this checks against. This means that anyone who uses it is not getting a complete OFAC check verification on any name they type in.

As a matter of fact, they will be removing this link from their website offerings soon.
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