Has anyone experienced a slow down in the turnaround time that OFAC returns calls?

Sometimes it is two weeks before I hear from them.

Join the club...I waited three weeks recently.

I've called once and never got a return call.

I have called at least 6 times and never got a call back. I also emailed and got nothing in return.

Glad they are sooooo worried about that list!

You people are scaring me...what are you doing with the transactions all this time that 'OFAC is not calling back'?

The accounts that are affected are loan only customers at my institution...so I haven't done anything to date except document, document, document.

If it turns out a loan customer is on the OFAC list, are you still allowed to accept payments from them??? Wouldn't that be considered "doing business" with someone on the OFAC list?

Well, I asked that question at a seminar that Professional Bank Services did and they said there is no guidance for that type of activity...so...I don't know...which is why I was calling OFAC to begin with.

PLUS- I would like the think whatever bank the checks are being written from would be picking them up on OFAC as well.

?????

My questions have been regarding the OFAC country sancitons. We are receiving wires via Tunisia originated in the Ivory Coast which is an OFAC sanctioned country. I feel that it is okay since the wire was not directly from the IC, but I wanted to make sure.

I have called twice on this without a return call.

Also, I have had a couple of extremely close hits from the OFAC data base scrub and they rarely return these calls either.

I know of a bank with a loan to someone on the SDN list (existing loan / person placed on the list after origination). They place the loan payments in a blocked account and file annual reports to OFAC. This has been going on for about 3 years. I don't have any more details on this, though. Not sure if OFAC advised them to handle the payments in this manner.

Although it sometimes takes awhile to hear back from OFAC, I find that doing your homework before you make that call helps to expedite the process. It also helps to leave a detailed message, which really helps in case they call you back while you are away from the desk.

Regarding the earlier post about wires from Ivory Coast, if you've read those sanctions you know that they pretty much pertain to certain persons or entities who have been incorporated into the SDN list. Do you have any reason to believe the wires were sent from (or sent from someone who is connected with) one of those persons or entities? Unless you probe more deeply into the source of the transactions, I don't know what more OFAC would be able to tell you, which might explain why you haven't heard back from them.

Ditto.

Ditto.

I actually have had to contact OFAC on a few transactions in the past and I had good results from them. Sometimes they may seem like they talk down to you for the question, but I have never had them flat out not call back timely.

I would contact your primary regulator and make them aware of your situation and request their guidance. They are going to be the primary party to isse CMPs for non-compliance with OFAC so if they are fine with what you are doing, as long as it is documented, you are off the hook.