I know that we can report any potential terrorists to OFAC but what about the FBI? If we have a name match against the FBI's most wanted list, are we able to contact the FBI to verify if it is a positive match or not? I want to make sure that doesn't fall under Privacy. Thanks.

You're matching your customer's names to teh FBI's most wanted list, or the control list?

If it is the control list, the istructions are clear as to actions, but not so much as what is a "match". The instructions do state, "...while not identical to any of the names, variations or aliases on the Control List, are sufficiently similar as to suggest that they may be the same individual or entity. We encourage you to err on the side of reporting and to treat such hits as a match to the name on the Control List."

And, "If your institution finds that it has any information concerning an individual or entity on the Control List, we ask that you immediately send an email message to suspicious.accounts@ny.frb.org identifying yourself and your institution and stating only that you have a positive response to the Control List."

Potential terrorists just with a name match would be reported to OFAC. If a person's activity is suspicious, warranting a SAR, then FBI is notified. I believe that if you have a legitimate name match, OFAC will get the FBI involved.

We use Bridger Systems Homeland Tracker to check for matches on the OFAC list. But there is also the FBI's list of most wanted, bank robbers, etc that is available for us to check. Which would be nice to know if we had a bank robber as a customer. OFAC says they don't have anything to do with those names and that we would need to call the FBI. So, if I do, will I break the privacy rule? Thanks.