If funds are temporarily blocked due to a 95% positive OFAC hit but it is later determined that the hit was false and the funds are released within 8 days, does this still need to be reported to OFAC?
NewTooBSA
Platinum Poster
Joined: Nov 2005
Posts: 568
Texas
The FFIEC Exam manual says the funds have to be reported within 10 days of occurrance. If you determined that it was not a positive match, then there is nothing to report.
However, the funds were blocked for a short period of time. If OFAC was notified of this verbally, would it still need to be reported to OFAC on the annual report?
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