What are other banks doing with respect to cashing checks (drawn on their bank) for non-customers? There are both OFAC and BSA implications that come into play. But can we turn away checks that are drawn on us from being cashed? No way can we review the OFAC list for each non-customer. So how are other banks complying with OFAC, as well as the BSA requirements?

why not? the OFAC list should be accessable from every terminal in the bank -- quickly tyoe in the name and get an immediate response.

In the ideal world, perhaps every bank would OFAC-check every payee for whom they are asked to cash an on-us check. In the real world, however, the OFAC check is often not so matter-of-fact or readily accessible.

OFAC-checking is, after all, a risk management tool. Of course, if you learn that the payee standing in front of you is an OFAC listee (or you suspect (s)he is), you need to block the transaction until you can get an OK. You might also have to prevent access to the funds by retaining the check and refusing to cash it unless you can get an OFAC clearance.

While I will agree with the fact that a bank can get in great trouble for allowing a blocked transaction to be completed, I am concerned with the thinking that says you have to check every party to every transaction your bank handles. It simply isn't possible for many banks to do that without bringing the bank to its processing knees. So you look at OFAC-checking as a risk management tool, and decide which transactions will be checked.

Obviously, large dollar value items will get high priority. Things like wires, loans, and opening accounts.