My bank is roughly 850M in assets w/15 banking center locations. Just formed recently (last few months) a BSA dept w/3 FT employees (including myself) and 1 PT employee. So we're still "feeling" our way and establishing duties.

Currently our IT dept performs the OFAC database scans via interdiction software and they want to move the function to the BSA dept. (I don't think so!!!).

But I wanted to get some feedback to see if this function is done within the BSA depts at other banks in our peer size. We're also implementing BSA/AML software at this time. SO our buckets are loaded......

Typically, the operations department controls the customer database and performs the OFAC scrubs.

Our scan is done automatically behind the scenes at night. BSA is part of the Operational Risk Management department and that is where the results of the scan are reviewed daily.

Ditto Here...

*ditto*

Scan done automatically, BSA department reviews suspects.

Thanks for the feedback!!