Quote: I sit here in awe of you that are able to get this past your management. I have a hard enough time getting everyone on board that they have to complete the CTR while the customer "waits" instead of completing them at the end of the day. There is no way our branch efficency team would want me to suggest they have to run an OFAC check each time a check is cashed for a non-customer.
McGruff - What type of software do your tellers use that has this built into it?
Management understands that a potential 6 figure pentalty far outweighs a few customers having to wait an extra couple of minutes. I would alert management to the potential pitfalls of doing business with an OFAC sanctioned party.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu
And if they don't understand, you can show them a spreadsheet of OFAC fines and penalites assessed against financial institutions that didn't have a good process, or any process. Start with the $40MM ABN-Amro fine.
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