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#774543 - 07/13/07 05:21 PM How would you handle this? (OFAC)
i*sam Offline
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i*sam
Joined: May 2007
Posts: 166
Southern California
#1-- You have an account for your customer who IS NOT on the OFAC list. A wire comes in for deposit to your customer's account but the originator is on OFAC.
-----Assuming this is a blocking issue and not a rejecting issue, would you put the funds in the account and then block or would you put the wire in a separate account and block?

#2-- Same scenario, but instead of a wire, you are receiving a cashier's check payable to your customer and the remitter is on OFAC.
-----Assuming this is a blocking issue and not a rejecting issue, would you put the funds in the account and then block or would you put the check in a separate account and block?
Last edited by Ken_Pegasus; 07/16/07 12:16 PM.
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#774605 - 07/13/07 05:48 PM Re: How would you handle this? i*sam
MagicCity Offline

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MagicCity
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Fort Lauderdale, Florida
FROM OFAC:
Title to the blocked property remains with the target, but the exercise of powers and privileges normally associated with ownership is prohibited without authorization from OFAC.


So the answer would be to put the funds into the account and freeze the account.

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#774641 - 07/13/07 05:58 PM Re: How would you handle this? MagicCity
John Burnett Offline
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Cape Cod
Correction, I think ... You don't want to freeze the entire account. It doesn't belong to the blocked party. Put the funds in an interest-bearing account separate from the one currently open, and freeze it.
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#774841 - 07/13/07 07:05 PM Re: How would you handle this? John Burnett
MagicCity Offline

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MagicCity
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Fort Lauderdale, Florida
Correct.
The funds have to go into an interest bearing account in the name of the person on OFAC.
I did not mean to imply that it could be mixed with other funds.

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#775387 - 07/13/07 11:09 PM Re: How would you handle this? John Burnett
HappyGilmore Offline
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Pulling people out of the ditc...
Quote:
Put the funds in an interest-bearing account separate from the one currently open, and freeze it.


Then contact OFAC with the payment information and request permission to release (this may have been an understood)
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