The question has come up about the need to do OFAC checks on government agencies. We currently do an OFAC check on any non-customer that is the payee of a Cashier Check from one of our customers. Has it ever been stated what to do when the payee is a local or state government agency or tresuary department?

Any advice or a point in the right direction for this situation will be greatly appreciated.

Thanks,

L.

Gosh, I hope the Treasury Department isn't on the OFAC list. We could all be in trouble!

Three comments:

1. It's next to impossible you will ever get an OFAC hit on a true domestic government entity.
2. It's possible that something that looks like a domestic government entity will be something else entirely (not likely, but possible).
3. Complicating a general instruction such as "check all payees for official check sales" with exceptions ("except for units of domestic government") could prove confusing and more trouble than it's worth.

And your auditor or examiner will probably want to see the print out of the OFAC check that was done on the Office of Foreign Assets Control.

Thanks for the responses. Helps to solidify my arguement that they should still be done.