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#91292 - 06/25/03 01:23 PM OFAC Screening
banksconsultus Offline
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banksconsultus
Joined: May 2002
Posts: 15
Los Angeles, California
One of our local Banks was just cited during their OCC BSA Examination for failing to complete an OFAC screen on legal processes? have any of you experts experienced a similar exception from the OCC?

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#91293 - 06/25/03 01:43 PM Re: OFAC Screening
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,294
Galveston, TX
Are you saying that you get, say a subpoena for account information on John Doe, that they are wanting evidence that you ran John Doe through the OFAC list?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#91294 - 06/25/03 01:50 PM Re: OFAC Screening
Anonymous
Unregistered

Yes. Including legal processes where the bank would potentially remit monies.

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#91295 - 06/25/03 02:07 PM Re: OFAC Screening
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,294
Galveston, TX
Don't you already scrub your current customer base? Why would this be different than paying a check that was presented against an account? I think they are on a fishing expedition.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#91296 - 06/25/03 02:21 PM Re: OFAC Screening
Anonymous
Unregistered

Yes, account scrubs are completed on a regular basis.

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#91297 - 06/25/03 02:23 PM Re: OFAC Screening
DeeQ Offline
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DeeQ
Joined: Dec 2002
Posts: 40,764
Turnpike Exit 10
Quote:

Yes. Including legal processes where the bank would potentially remit monies.



Such as levies/liens? Never did on the receipt of such items. All CIFs are scrubbed for OFAC, as well as new accounts. Are they referring to the recipient of the levy proceeds?
I would ask them where they came up with that one, of course, in a nice way.
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Get your facts first, then you can distort them as you please. - Mark Twain

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#91298 - 06/25/03 02:43 PM Re: OFAC Screening
Anonymous
Unregistered

The local bank did ask where the authority was drawn from. The OCC indicated that it was in their BSA Handbook. I looked and couldn't find any such referrence.

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#91299 - 06/25/03 02:48 PM Re: OFAC Screening
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,294
Galveston, TX
They need to go back the examiner and get some specifics, because I too looked and couldn't find it.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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