We open (or rather - we have opened) accounts for students that attend a Seminary School in our area and some of those students list their permanent resident address on the W-8Ben as countries such as Iran, Sudan, etc. The bank's interdiction system never picks up the country name because a local address is used when the account is opened. We had to "restrict" an account when an individual changed his mailing addres to Iran. Someone from OFAC Compliance told me that IF an Iranian is in the United States the Bank can do business with him; but when he goes back to IRAN the bank CANNOT do business with him. (Try to find that in the Sanction Matrix - I dare you)...Anyway...I'm desperate for taining material addressing this type of situation. We have made it a policy to not open accounts for individuals with a permanent address of IRAN because we do not want to be placed in a position of keeping tract of their whereabouts while the account is open (in the U.S. or in Iran). HOWEVER, could/should we apply this rule to anyone wishing to open an account that has a permanent address in any of the OFAC Sanctioned Countries???? And, if we do open the account, must we "restrict" and report the account to OFAC annually?